Ohio Farm Bureau Federation, Inc. - Page 3

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          section 6621(c),1 dealing with large corporate underpayments, for           
          the taxable period ending August 31, 1985.                                  

                                  FINDINGS OF FACT                                    

               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and attached exhibits are incorporated             
          herein by this reference.  At the time the petition was filed,              
          petitioner’s principal place of business was in Columbus, Ohio.             
               Petitioner is the Ohio Farm Bureau Federation, Inc., a                 
          nonprofit agricultural organization exempt from Federal income              
          tax under section 501(c)(5).  Petitioner was formed in 1919 as an           
          unincorporated association and subsequently incorporated under              
          Ohio law on November 27, 1931.  Petitioner is a statewide                   
          federation of local county farm bureaus (county bureaus).                   
          Individual farmers are not members of petitioner.  Instead,                 
          farmers (or other persons fulfilling certain eligibility                    
          requirements) are members of the county bureaus, which, in turn,            
          are members of petitioner.                                                  
               Petitioner’s stated purpose was generally to aid and assist            
          in the betterment of the conditions and welfare of those engaged            
          in agriculture.  More specifically, petitioner engaged in                   
          activities to educate Ohio farmers and to promote agricultural              

          1Unless otherwise indicated, all section references are to                  
          the Internal Revenue Code in effect for the taxable period in               
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     




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