Cloquet Coop. Society v. Commissioner
United States Board of Tax Appeals
1. DEDUCTION - INTEREST. - The petitioner, a cooperative corporation, paid a fixed rate of 6 per cent on its shares of stock. Held, that such amounts constituted dividends and not interest on loans. 2. TAXES - ACCRUED. - Petitioner's taxes for the years 1924 and 1925, deductible from gross income, accrued in those years respectively. The petitioner kept its books and made its returns on the accrual basis.
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1. DEDUCTION - INTEREST. - The petitioner, a cooperative corporation, paid a fixed rate of 6 per cent on its shares of stock. Held, that such amounts constituted dividends and not interest on loans. 2. TAXES - ACCRUED. - Petitioner's taxes for the years 1924 and 1925, deductible from gross income, accrued in those years respectively. The petitioner kept its books and made its returns on the accrual basis. Held, that such taxes should be deducted in each of those years respectively.
1Opinion of the Court
MEMORANDUM.
TRUSSell:
The appeal, Docket No. 39021, is from the respondent’s determination of a deficiency in the amount of $625.85 in petitioner’s income taxes for the years 1924 and 1925, the said deficiency resulting from the respondent’s (1) disallowance as an interest deduction in each year, the 6 per cent paid on petitioner’s outstanding capital stock, and (2) his disallowance of a deduction in 1924 and 1925 for taxes for those, years, the said taxes having been ascertained as to amount and accrued on petitioner’s books for each year although not actually paid until 1925 and 1926,…
2Cases cited2 opinions
- State v. Northwestern Telephone Exchange Co.Supreme Court of Minnesota · 1900
- National Bond & Security Co. v. HopkinsSupreme Court of Minnesota · 1905
3Cited by9 opinions
- Union Equity Cooperative Exchange v. CommissionerUnited States Tax Court · 1972
- Lifson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1938
- Bakers' Mut. Co-operative Asso. v. CommissionerUnited States Board of Tax Appeals · 1939
- Cloquet Coop. Society v. CommissionerUnited States Board of Tax Appeals · 1930
- Leamington Hotel Co. v. CommissionerUnited States Board of Tax Appeals · 1932
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