Legal Opinion

Linnton Plywood Ass'n v. United States

District Court, D. Oregon

Decided March 30, 1976No. Civ. 73-982, 73-1017PublishedCited by 7 opinions

1Opinion of the Court

SOLOMON, District Judge:

The plaintiffs are two workers’ cooperatives which manufacture and market plywood and plywood byproducts. They seek refunds for the federal corporate income taxes they paid.

I. The Statute

Subchapter T of the Internal Revenue Code of 1954, 26 U.S.C. §§ 1381-1388, provides special tax treatment for cooperatives. During the tax years involved here (the tax years), both plaintiffs qualified for Subchapter T treatment. 26 U.S.C. § 1381(a)(2); Linnton Plywood Association v. United States, 236 F.Supp. 227 (D.Or.1964); Puget Sound Plywood, Inc. v. Commissioner, 44 T.C. 305…

2Cases cited5 opinions

  1. Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
  2. Ox Fibre Brush Co. v. BlairCourt of Appeals for the Fourth Circuit · 1929
  3. Puget Sound Plywood, Inc. v. CommissionerUnited States Tax Court · 1965
  4. Alan W. Ladd and Sue Carol Ladd v. Robert A. Riddell, District Director of Internal Revenue, Los Angeles, California, Etc.Court of Appeals for the Ninth Circuit · 1962
  5. Linnton Plywood Association v. United StatesDistrict Court, D. Oregon · 1964

3Cited by7 opinions

  1. St. Louis Bank for Cooperatives v. United StatesUnited States Court of Claims · 1980
  2. Illinois Grain Corp. v. CommissionerUnited States Tax Court · 1986
  3. Land O'lakes, Inc., Formerly Land O'Lakes Creameries, Inc., a Minnesota Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1982
  4. Cotter and Company and Subsidiaries v. The United StatesCourt of Appeals for the Federal Circuit · 1985
  5. CF Indus., Inc. v. CommissionerUnited States Tax Court · 1991

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