Legal Opinion

Caswell v. Commissioner

United States Tax Court

Decided January 18, 1952No. Docket Nos. 27017, 27018Published

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

Estate of Wallace Caswell, Deceased, Jennie J. Caswell, Administratrix, Petitioner, v. Commissioner of Internal Revenue, Respondent. Estate of Charles Henry Caswell, Deceased, Earl W. Caswell, Administrator, Petitioner, v. Commissioner of Internal Revenue, Respondent

Caswell v. Commissioner

Docket Nos. 27017, 27018

United States Tax Court

17 T.C. 1190; 1952 U.S. Tax Ct. LEXIS 290;

January 18, 1952, Promulgated

Decisions will be entered under Rule 50.

The petitioners were members of a cooperative growers association through which they marketed their peaches. Under the marketing plan, the peaches were…

2Cases cited5 opinions

  1. Harbor Plywood Corp. v. CommissionerUnited States Tax Court · 1950
  2. San Joaquin Valley Poultry Producers' Ass'n v. CommissionerCourt of Appeals for the Ninth Circuit · 1943
  3. Colony Farms Cooperative Dairy, Inc. v. CommissionerUnited States Tax Court · 1951
  4. Caswell v. CommissionerUnited States Tax Court · 1952
  5. Phillips v. CommissionerUnited States Tax Court · 1951

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