Legal Opinion

Greenvine Corp. v. Commissioner

United States Tax Court

Decided September 6, 1963No. Docket No. 88771Published

Petitioner, a California corporation, purchased certain revolving fund credits at a discount from Culbertson, an agricultural cooperative packing house. Such credits had been acquired by Culbertson as a member of ELPC, a cooperative marketing association which produced and marketed lemon byproducts for its members.

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Petitioner, a California corporation, purchased certain revolving fund credits at a discount from Culbertson, an agricultural cooperative packing house. Such credits had been acquired by Culbertson as a member of ELPC, a cooperative marketing association which produced and marketed lemon byproducts for its members. In accordance with established industry practice, ELPC retained specific sums from the proceeds of members' fruit processed through the cooperative to acquire funds with which to operate its business. As additional funds were acquired so that the total amount of the fund exceeded…

1Opinion of the Court

Greenvine Corporation, a California Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Greenvine Corp. v. Commissioner

Docket No. 88771

United States Tax Court

40 T.C. 926; 1963 U.S. Tax Ct. LEXIS 60;

September 6, 1963, Filed

Decision will be entered under Rule 50.

Petitioner, a California corporation, purchased certain revolving fund credits at a discount from Culbertson, an agricultural cooperative packing house. Such credits had been acquired by Culbertson as a member of ELPC, a cooperative marketing association which produced and marketed lemon byproducts for its members.…

2Cases cited13 opinions

  1. Long Poultry Farms, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
  2. Commissioner of Internal Revenue v. B. A. CarpenterCourt of Appeals for the Fifth Circuit · 1955
  3. Carpenter v. CommissionerUnited States Tax Court · 1953
  4. Gerard v. HelveringCourt of Appeals for the Second Circuit · 1941
  5. Richard T. Graham v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962

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