Legal Opinion

Gold Kist v. Commissioner

United States Tax Court

Decided June 26, 1995No. Docket No. 10768-93Published

P, a taxable farmers cooperative, distributed patronage dividends to its patrons annually in accordance with its bylaws. Some of the patronage dividends were issued as qualified written notices of allocation as defined in sec. 1388(c)(1), I.R.C. Patrons included the stated amounts of the qualified written notices of allocation in their gross income. P deducted the stated amounts of the qualified written notices of allocation under sec. 1382(b), I.R.C.

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P, a taxable farmers cooperative, distributed patronage dividends to its patrons annually in accordance with its bylaws. Some of the patronage dividends were issued as qualified written notices of allocation as defined in sec. 1388(c)(1), I.R.C. Patrons included the stated amounts of the qualified written notices of allocation in their gross income. P deducted the stated amounts of the qualified written notices of allocation under sec. 1382(b), I.R.C. P adopted a policy of redeeming terminating patrons' qualified written notices of allocation upon written demand. In a redemption, P pays cash…

1Opinion of the Court

Gold Kist Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Gold Kist v. Commissioner

Docket No. 10768-93

United States Tax Court

104 T.C. 696; 1995 U.S. Tax Ct. LEXIS 34; 104 T.C. No. 34;

June 26, 1995, Filed

Decision will be entered under Rule 155.

P, a taxable farmers cooperative, distributed patronage dividends to its patrons annually in accordance with its bylaws. Some of the patronage dividends were issued as qualified written notices of allocation as defined in sec. 1388(c)(1), I.R.C. Patrons included the stated amounts of the qualified written notices of allocation in their…

2Cases cited20 opinions

  1. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  2. Humes v. United StatesSupreme Court of the United States · 1928
  3. Hillsboro National Bank v. CommissionerSupreme Court of the United States · 1983
  4. Arkansas Best Corp. v. CommissionerSupreme Court of the United States · 1988
  5. Segel v. CommissionerUnited States Tax Court · 1987

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