Legal Opinion

Concord Consumers Hous. Coop. v. Commissioner

United States Tax Court

Decided July 16, 1987No. Docket No. 31365-81PublishedCited by 50 opinions

P is a federally subsidized, nonexempt, nonprofit corporation organized to provide housing for persons of low and moderate incomes.

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P is a federally subsidized, nonexempt, nonprofit corporation organized to provide housing for persons of low and moderate incomes. P earned interest income on two reserve accounts and on an escrow account it was required to maintain under its agreements with the Federal Housing Administration (FHA) and the Michigan State Housing Development Authority (MSHDA). Held, interest income earned on those accounts is not "income derived * * * from members or transactions with members" within the meaning of sec. 277(a), I.R.C. 1954, and constitutes nonmembership income. Held, further, expenses…

1Opinion of the Court

PARKER, Judge:

Respondent determined deficiencies in petitioner’s Federal income tax as follows:

TYE Mar. Si-Deficiency

1976 . $4,399

1977 . 3,036

1978 . 3,865

After concessions1 the issues remaining for decision are:(1) Whether the interest petitioner earned on two reserve accounts and a mortgage escrow account required to be established pursuant to regulatory agreements with the Federal Housing Administration and the Michigan State Housing Development Authority constitutes income “derived * * * from members or transactions with members” (membership income) within the meaning of section 277(a);2…

2Cases cited21 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  3. United States v. American Bar EndowmentSupreme Court of the United States · 1986
  4. United States v. American College of PhysiciansSupreme Court of the United States · 1986
  5. Graff v. CommissionerUnited States Tax Court · 1980

16 more not listed; retrieve them via the Exa API.

3Cited by50 opinions

  1. Thomas v. CommissionerUnited States Tax Court · 1989
  2. Foil v. CommissionerUnited States Tax Court · 1989
  3. Conti v. CommissionerUnited States Tax Court · 1992
  4. Bussing v. CommissionerUnited States Tax Court · 1987
  5. Metrocorp, Inc. v. CommissionerUnited States Tax Court · 2001

45 more not listed; retrieve them via the Exa API.

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