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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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