Legal Opinion

Helena Cotton Oil Co. v. Commissioner

United States Tax Court

Decided April 25, 1973No. Docket No. 3519-71Published

Held, that the petitioner, a cooperative organization, has no qualified investment in sec. 38 property for the fiscal year ended July 31, 1968, and, therefore, has no unused investment credit for carryback and carryover purposes where it incurred a net operating loss and paid no patronage dividends or made other distributions during that fiscal year.

1Opinion of the Court

Helena Cotton Oil Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Helena Cotton Oil Co. v. Commissioner

Docket No. 3519-71

United States Tax Court

60 T.C. 125; 1973 U.S. Tax Ct. LEXIS 138; 60 T.C. No. 16;

April 25, 1973, Filed

Decision will be entered under Rule 50.

Held, that the petitioner, a cooperative organization, has no qualified investment in sec. 38 property for the fiscal year ended July 31, 1968, and, therefore, has no unused investment credit for carryback and carryover purposes where it incurred a net operating loss and paid no patronage dividends or made other…

2Cases cited1 opinion

  1. Helena Cotton Oil Co. v. CommissionerUnited States Tax Court · 1973

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