Legal Opinion

Rocco, Inc. v. Commissioner

United States Tax Court

Decided April 23, 1979No. Docket Nos. 4328-75, 4329-75, 4330-75Published

Rocco, Inc., the parent corporation, operated primarily as a poultry feed mill and contract grower of poultry, principally broilers. In 1971, for business reasons, Rocco, Inc., decided to go into the broiler processing business. Rocco, Inc., and Marval, a turkey processor and customer of Rocco, Inc., formed Rocco Farm Foods, Inc., to operate the broiler processing business, Rocco, Inc., acquiring 80 percent of the stock and Marval 20 percent of the stock of Farm Foods.

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Rocco, Inc., the parent corporation, operated primarily as a poultry feed mill and contract grower of poultry, principally broilers. In 1971, for business reasons, Rocco, Inc., decided to go into the broiler processing business. Rocco, Inc., and Marval, a turkey processor and customer of Rocco, Inc., formed Rocco Farm Foods, Inc., to operate the broiler processing business, Rocco, Inc., acquiring 80 percent of the stock and Marval 20 percent of the stock of Farm Foods. Rocco Broiler Farms was then formed as a wholly owned subsidiary of Farm Foods, to raise the broilers which were sold to Farm…

1Opinion of the Court

Rocco, Inc. (Formerly Rocco Feeds, Inc.), et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Rocco, Inc. v. Commissioner

Docket Nos. 4328-75, 4329-75, 4330-75

United States Tax Court

72 T.C. 140; 1979 U.S. Tax Ct. LEXIS 133;

April 23, 1979, Filed

Decisions will be entered under Rule 155.

Rocco, Inc., the parent corporation, operated primarily as a poultry feed mill and contract grower of poultry, principally broilers. In 1971, for business reasons, Rocco, Inc., decided to go into the broiler processing business. Rocco, Inc., and Marval, a turkey processor and customer of Rocco,…

2Cases cited21 opinions

  1. Higgins v. SmithSupreme Court of the United States · 1940
  2. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
  3. United States v. CattoSupreme Court of the United States · 1966
  4. Van Raden v. CommissionerUnited States Tax Court · 1979
  5. Alinco Life Insurance Company v. The United StatesUnited States Court of Claims · 1967

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