Des Moines County Farm Service Company v. United States

PER CURIAM. •

This is a suit instituted by Des Moines County Farm Service Company, a non-exempt (under Subehapter T of the Internal Revenue Code of 1954, 26 U.S.C. § 1381, et seq.) marketing and purchasing farmers cooperative organization seeking refunds on federal income taxes paid by it for fiscal years 1964 and 1965. The issue on appeal was stipulated by the parties as follows: “Whether in computing [taxpayer’s] allowable patronage dividend deduction for federal income tax purposes, cash dividends on capital stock may be deducted solely from [taxpayer’s] nonmember and non-patronage income,…