Bot v. Comm'r
United States Tax Court
Ps maintained active memberships in an agricultural cooperative, which processed and sold corn produced by its members. As active members, Ps were obligated to produce and deliver corn to the cooperative regularly, and, during 1994 and 1995, they met that obligation with corn they acquired from a "pool" maintained by the cooperative. The cooperative processed and sold the corn for Ps' benefit and paid to Ps value-added payments for the corn.
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Ps maintained active memberships in an agricultural cooperative, which processed and sold corn produced by its members. As active members, Ps were obligated to produce and deliver corn to the cooperative regularly, and, during 1994 and 1995, they met that obligation with corn they acquired from a "pool" maintained by the cooperative. The cooperative processed and sold the corn for Ps' benefit and paid to Ps value-added payments for the corn. For Federal tax purposes, Ps reported the value-added payments they received during 1994 and 1995 as proceeds from the sale of capital assets and did not…
1Opinion of the Court
Marvel, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax for 1994 and 1995 of $7,239 and $13,716, respectively.
The sole issue for decision is whether petitioners are liable for self-employment tax under section 14011 on value-added payments that they received in 1994 and 1995 from an agricultural cooperative of which they were active members.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts is incorporated in our opinion by this reference. Petitioners resided in Marshall, Minnesota, when the petition in this case was…
2Cases cited10 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Newberry v. CommissionerUnited States Tax Court · 1981
- Jurek v. ThompsonSupreme Court of Minnesota · 1976
5 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Anderson v. Comm'rUnited States Tax Court · 2004
- Morehouse v. CommissionerUnited States Tax Court · 2013
- Anderson v. Comm'rUnited States Tax Court · 2004
- Bot v. Comm'rUnited States Tax Court · 2002
- Chai v. Comm'rUnited States Tax Court · 2015
10 more not listed; retrieve them via the Exa API.