Kingfisher Cooperative Elevator Asso. v. Commissioner
United States Tax Court
Petitioner, a local farmers' cooperative, included patronage dividends received from regional cooperatives of which it was a member in its gross income in the year of receipt. In computing its patronage dividends for its member-patrons for fiscal year 1981, petitioner allocated net income to its patrons according to their patronage during that year. Petitioner's allocation was adopted by its board of directors and ratified annually by its members.
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Petitioner, a local farmers' cooperative, included patronage dividends received from regional cooperatives of which it was a member in its gross income in the year of receipt. In computing its patronage dividends for its member-patrons for fiscal year 1981, petitioner allocated net income to its patrons according to their patronage during that year. Petitioner's allocation was adopted by its board of directors and ratified annually by its members. Held, petitioner's allocation method was equitable considering the stability of its membership, the practicalities of the allocation, and the…
1Opinion of the Court
Kingfisher Cooperative Elevator Association, Petitioner v. Commissioner of Internal Revenue, Respondent
Kingfisher Cooperative Elevator Asso. v. Commissioner
Docket No. 5569-83
United States Tax Court
84 T.C. 600; 1985 U.S. Tax Ct. LEXIS 99; 84 T.C. No. 39;
April 2, 1985. April 2, 1985, Filed
Decision will be entered for the petitioner.
Petitioner, a local farmers' cooperative, included patronage dividends received from regional cooperatives of which it was a member in its gross income in the year of receipt. In computing its patronage dividends for its member-patrons for fiscal year 1981,…
2Cases cited11 opinions
- Union Equity Cooperative Exchange v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973
- Union Equity Cooperative Exchange v. CommissionerUnited States Tax Court · 1972
- United Grocers, Ltd. v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- United Grocers, Ltd. v. United StatesDistrict Court, N.D. California · 1960
- Farmers Union Co-Op. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1937
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