West Central Cooperative v. United States

West Central Cooperative (taxpayer) appeals from a final judgment entered in the District Court 1 for the Northern District of Iowa denying taxpayer’s petition seeking a refund of additional taxes assessed because of the withdrawal of taxpayer’s exemption as a farmers’ cooperative pursuant to 26 U.S.C. § 521(b)(2) (1982). For reversal taxpayer argues that the district court erred in (1) holding that the percentage of taxpayer’s voting stock held by producers did not constitute “substantially all” within the meaning of 26 U.S.C. § 521(b)(2), (2) imposing an annual patronage test in determining…