Helena Cotton Oil Co. v. Commissioner
United States Tax Court
Held, that the petitioner, a cooperative organization, has no qualified investment in sec. 38 property for the fiscal year ended July 31, 1968, and, therefore, has no unused investment credit for carryback and carryover purposes where it incurred a net operating loss and paid no patronage dividends or made other distributions during that fiscal year.
1Opinion of the Court
opinion
Dawson, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
TYE July SI— 1965 _ 1966 _ 1967 - Deficiency $2, 915.38 2, 619.19 1,269.09
Some issues are not in dispute and the parties have agreed that there are certain deficiencies for the first 2 taxable years. The only issue remaining for decision relates to respondent’s disallowance of an investment credit carryback from the fiscal year ended July 31, 1968. We must decide whether the petitioner, a cooperative organization which paid no patronage dividends or made other distributions during the…
2Cited by3 opinions
- Farmers Grain Marketing Terminal (AAL) v. United StatesDistrict Court, N.D. Mississippi · 1977
- Farm Bureau Services, Inc. v. United StatesDistrict Court, W.D. Michigan · 1982
- Helena Cotton Oil Co. v. CommissionerUnited States Tax Court · 1973