Legal Opinion
Land O'Lakes, Inc. v. United States
District Court, D. Minnesota
Decided May 17, 1979No. Civ. 3-71-49PublishedCited by 2 opinions
1Opinion of the Court
MEMORANDUM & ORDER
DEVITT, Chief Judge.
This action is brought by plaintiff taxpayer, Land O’Lakes, a Minnesota cooperative, for refund of income taxes paid in 1963. Plaintiff is a “non-exempt cooperative,” a status which allows it to deduct “patronage dividends” from its gross earnings, subject to the restrictions of Subchapter T of the Internal Revenue Code. See 26 U.S.C. §§ 1381-88 (1976). Patronage dividends, simply stated, are dividends paid to the patrons of the cooperative from the cooperative’s net earnings. This matter is before the court on remand from the Court of Appeals for the…
2Cases cited7 opinions
- Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
- Union Equity Cooperative Exchange v. CommissionerUnited States Tax Court · 1972
- Pomeroy Cooperative Grain Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961
- United States v. Mississippi Chemical CompanyCourt of Appeals for the Fifth Circuit · 1964
- Land O'lakes, Inc., Formerly Land O'Lakes Creameries, Inc., a Minnesota Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1975
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3Cited by2 opinions
- Land O'lakes, Inc., Formerly Land O'Lakes Creameries, Inc., a Minnesota Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1982
- Caldwell Sugars Co-op., Inc. v. United StatesDistrict Court, E.D. Louisiana · 1988