Legal Opinion

Ford-Iroquois FS, Inc. v. Commissioner

United States Tax Court

Decided September 9, 1980No. Docket No. 11979-77Published

Petitioner, a nonexempt agricultural cooperative, operates both a grain department and an agricultural supply department. The grain department performs selling and storage functions while the supply department sells petroleum, fertilizer, feed, and other products. Both departments do business with cooperative members and nonmembers.

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Petitioner, a nonexempt agricultural cooperative, operates both a grain department and an agricultural supply department. The grain department performs selling and storage functions while the supply department sells petroleum, fertilizer, feed, and other products. Both departments do business with cooperative members and nonmembers. During two "short periods" in 1971 and the calendar year 1972, petitioner and Ford County FS, Inc. (which merged into petitioner on Jan. 31, 1971), reported net operating losses. The board of directors and managers of petitioner elected to carry forward and offset…

1Opinion of the Court

Ford-Iroquois FS, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Ford-Iroquois FS, Inc. v. Commissioner

Docket No. 11979-77

United States Tax Court

74 T.C. 1213; 1980 U.S. Tax Ct. LEXIS 70;

September 9, 1980, Filed

Decision will be entered under Rule 155.

Petitioner, a nonexempt agricultural cooperative, operates both a grain department and an agricultural supply department. The grain department performs selling and storage functions while the supply department sells petroleum, fertilizer, feed, and other products. Both departments do business with cooperative members and…

2Cases cited14 opinions

  1. Frost v. Corporation Comm'n of Okla.Supreme Court of the United States · 1929
  2. Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
  3. Union Equity Cooperative Exchange v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973
  4. Union Equity Cooperative Exchange v. CommissionerUnited States Tax Court · 1972
  5. United States v. Mississippi Chemical CompanyCourt of Appeals for the Fifth Circuit · 1964

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