Caswell v. Commissioner
United States Tax Court
The petitioners were members of a cooperative growers association through which they marketed their peaches. Under the marketing plan, the peaches were placed in a pool with peaches of like kind, grade, and classification produced by other members. When the peaches were sold and the pool was closed, the net proceeds, less an association charge, were distributed to the members on the basis of participation.
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The petitioners were members of a cooperative growers association through which they marketed their peaches. Under the marketing plan, the peaches were placed in a pool with peaches of like kind, grade, and classification produced by other members. When the peaches were sold and the pool was closed, the net proceeds, less an association charge, were distributed to the members on the basis of participation. The association charge, after payment of general organization and association expenses, was carried into a capital reserve and, in addition to the cash distributed, the members also…
1Opinion of the Court
OPINION.
Turner, Judge:
The proceeding at Docket No. 27017, the Estate of Wallace Caswell, involves a deficiency in income tax for 1945 of $7,828.97, and that at Docket No, 27018, the Estafe of Charles Henry Caswell, a deficiency for the same year, of $5,278.10.
The primary issue presented is whether income was realized by the taxpayers in 1945 upon the receipt of certificates issued by a. cooperative association upon its commercial reserve fund, and if income was so realized, the question arises as to the fair market value of the certificates at the time they were received by the Caswells.…
2Cases cited4 opinions
- Harbor Plywood Corp. v. CommissionerUnited States Tax Court · 1950
- San Joaquin Valley Poultry Producers' Ass'n v. CommissionerCourt of Appeals for the Ninth Circuit · 1943
- Colony Farms Cooperative Dairy, Inc. v. CommissionerUnited States Tax Court · 1951
- Phillips v. CommissionerUnited States Tax Court · 1951
3Cited by10 opinions
- Carpenter v. CommissionerUnited States Tax Court · 1953
- Riverfront Groves, Inc. v. CommissionerUnited States Tax Court · 1973
- Caswell's Estate v. Commissioner of Internal Revenue (Two Cases)Court of Appeals for the Ninth Circuit · 1954
- Joplin v. CommissionerUnited States Tax Court · 1952
- Carpenter v. CommissionerUnited States Tax Court · 1953
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