Legal Opinion

Puget Sound Plywood, Inc. v. Commissioner

United States Tax Court

Decided June 4, 1965No. Docket No. 3933-62PublishedCited by 26 opinions

The petitioner was and is a cooperative association of the type commonly known as a workers cooperative association, which was incorporated and operated in accordance with a statute of the State of Washington that pertains particularly to the creation and regulation of associations operating on a cooperative basis.

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The petitioner was and is a cooperative association of the type commonly known as a workers cooperative association, which was incorporated and operated in accordance with a statute of the State of Washington that pertains particularly to the creation and regulation of associations operating on a cooperative basis. Held, that said cooperative association is entitled to be classified and treated for Federal income tax purposes, as a "nonexempt cooperative association"; and that as such, it is entitled to exclude from the proceeds of the association's operations, for Federal income tax…

1Opinion of the Court

Pierce, Judge:

The respondent determined deficiencies in income tax against the petitioner for the following years and in the following amounts:

Calendar year Deficiency

1958_$390,113.51

1959_ 520, 936. 08

1960_ 207, 538.17

The sole issue for decision herein is whether the petitioner, which is a cooperative association of the type commonly known as a workers cooperative association, that was incorporated and operated in accordance with a statute of the State of Washington that pertains particularly to the formation and regulation of associations operating on a cooperative basis: (1) Is entitled to…

2Cases cited13 opinions

  1. United States v. Magnolia Petroleum Co.Supreme Court of the United States · 1928
  2. Farmers Cooperative Co. v. BirminghamDistrict Court, N.D. Iowa · 1949
  3. Pomeroy Coop. Grain Co. v. CommissionerUnited States Tax Court · 1958
  4. Harbor Plywood Corp. v. CommissionerUnited States Tax Court · 1950
  5. Pomeroy Cooperative Grain Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961

8 more not listed; retrieve them via the Exa API.

3Cited by26 opinions

  1. Union Equity Cooperative Exchange v. CommissionerUnited States Tax Court · 1972
  2. Richard J. Bot Phyllis Bot v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2003
  3. Florists' Transworld Delivery Ass'n v. CommissionerUnited States Tax Court · 1976
  4. Bot v. Comm'rUnited States Tax Court · 2002
  5. Buckeye Countrymark v. CommissionerUnited States Tax Court · 1994

21 more not listed; retrieve them via the Exa API.

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