Ohio Farm Bureau Fed'n v. Commissioner
United States Tax Court
P, a tax-exempt agricultural organization, engaged in activities to promote the use of agricultural cooperatives among farmers. In 1934, P formed L, a statewide cooperative. In 1949, P and L entered into a written contract, whereby P agreed to perform educational and promotional activities on behalf of L in exchange for a fee. Pursuant to the contract, P performed activities to promote cooperatives in general and L specifically. In 1985, L merged into another cooperative.
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P, a tax-exempt agricultural organization, engaged in activities to promote the use of agricultural cooperatives among farmers. In 1934, P formed L, a statewide cooperative. In 1949, P and L entered into a written contract, whereby P agreed to perform educational and promotional activities on behalf of L in exchange for a fee. Pursuant to the contract, P performed activities to promote cooperatives in general and L specifically. In 1985, L merged into another cooperative. In connection with the merger, P and L formally terminated their contractual relationship pursuant to a written…
1Opinion of the Court
Ruwe, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax in the amounts of $1,107,505 and $40,192 for the taxable periods ending August ¡31, 1985, and August 31, 1986, respectively.
After concessions, the issues for decision are: (1) Whether the $292,617 received by petitioner pursuant to its service contract with Landmark, Inc., during the taxable year ending August 31, 1985, constituted unrelated business taxable income; (2) whether a lump-sum payment made by Landmark, Inc., to petitioner pursuant to the terms of a nonsponsorship and noncompetition clause contained…
2Cases cited18 opinions
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Helvering v. SalvageSupreme Court of the United States · 1936
- United States v. American Bar EndowmentSupreme Court of the United States · 1986
- United States v. American College of PhysiciansSupreme Court of the United States · 1986
- Louisiana Credit Union League v. The United States of AmericaCourt of Appeals for the Fifth Circuit · 1982
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3Cited by12 opinions
- Pen Coal Corp. v. CommissionerUnited States Tax Court · 1996
- Jackson v. CommissionerUnited States Tax Court · 1997
- Brown v. Director of RevenueSupreme Court of Missouri · 2000
- Free-Pacheco v. United StatesUnited States Court of Federal Claims · 2014
- Jackson v. CommissionerUnited States Tax Court · 1997
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