Carpenter v. Commissioner
United States Tax Court
1. Income -- Cooperative -- Revolving Fund Certificates. -- Amounts retained at sole discretion of board of directors for capital purposes evidenced by revolving fund certificates issued to members in payment of patronage dividends, which certificates bore no interest, were retirable at sole discretion of the directors, were subordinate to all other debts of the cooperative, and had no fair market value held, not to be income of members in year issued. 2. Income -- Year in…
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1. Income -- Cooperative -- Revolving Fund Certificates. -- Amounts retained at sole discretion of board of directors for capital purposes evidenced by revolving fund certificates issued to members in payment of patronage dividends, which certificates bore no interest, were retirable at sole discretion of the directors, were subordinate to all other debts of the cooperative, and had no fair market value held, not to be income of members in year issued. 2. Income -- Year in Which Taxable. -- Stock in another corporation purchased by a cooperative on behalf of its members out of earnings of the…
1Opinion of the Court
B. A. Carpenter, Petitioner, v. Commissioner of Internal Revenue, Respondent
Carpenter v. Commissioner
Docket No. 30631
United States Tax Court
20 T.C. 603; 1953 U.S. Tax Ct. LEXIS 122;
June 15, 1953, Promulgated
Decision will be entered under Rule 50.
1. Income -- Cooperative -- Revolving Fund Certificates. -- Amounts retained at sole discretion of board of directors for capital purposes evidenced by revolving fund certificates issued to members in payment of patronage dividends, which certificates bore no interest, were retirable at sole discretion of the directors, were subordinate to all other…
Also in this document: Dissent.
2Cases cited6 opinions
- Harbor Plywood Corp. v. CommissionerUnited States Tax Court · 1950
- Scientific Instrument Co. v. CommissionerUnited States Tax Court · 1952
- Marsh v. CommissionerUnited States Tax Court · 1949
- Carpenter v. CommissionerUnited States Tax Court · 1953
- Caswell v. CommissionerUnited States Tax Court · 1952
1 more not listed; retrieve them via the Exa API.