Union Equity Cooperative Exchange v. Commissioner
United States Tax Court
Petitioner was a nonexempt cooperative in its taxable year 1963 and an exempt cooperative in its taxable year 1964. In each year petitioner distributed a patronage dividend to its patrons and a dividend on capital stock to its stockholders.
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Petitioner was a nonexempt cooperative in its taxable year 1963 and an exempt cooperative in its taxable year 1964. In each year petitioner distributed a patronage dividend to its patrons and a dividend on capital stock to its stockholders. Held: (1) In its taxable year 1963 petitioner could not charge the dividend on capital stock solely to nonmember earnings, but had to charge such dividend to net earnings realized from member business and to net earnings realized from nonmember business in proportion to the business transacted with members and nonmembers respectively. (2) Respondent was…
1Opinion of the Court
Union Equity Cooperative Exchange, Petitioner v. Commissioner of Internal Revenue, Respondent
Union Equity Cooperative Exchange v. Commissioner
Docket No. 439-70
United States Tax Court
58 T.C. 397; 1972 U.S. Tax Ct. LEXIS 112;
May 31, 1972, Filed
Decision will be entered for the respondent.
Petitioner was a nonexempt cooperative in its taxable year 1963 and an exempt cooperative in its taxable year 1964. In each year petitioner distributed a patronage dividend to its patrons and a dividend on capital stock to its stockholders. Held: (1) In its taxable year 1963 petitioner could not charge the…
2Cases cited47 opinions
- Polachek v. CommissionerUnited States Tax Court · 1954
- Rose v. CommissionerUnited States Tax Court · 1970
- George R. Tollefsen and Margaret A. Tollefsen v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- Farmers Cooperative Co. v. BirminghamDistrict Court, N.D. Iowa · 1949
- Neri v. CommissionerUnited States Tax Court · 1970
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