2 MEMORANDUM OPINION COLVIN, Judge: Respondent determined deficiencies in petitioner's Federal income tax of $8,117 for 1989 and $6,606 for 1990. The issues for decision are: 1. Whether petitioner, a housing cooperative under section 216, is subject to subchapter T (sections 1381-1388), aspetitioner contends, or is a membership organization under section 277, as respondent contends. We hold that petitioner is subject to subchapter T and is not subject to section 277. 2. Whether interest income earned by petitioner is patronage sourced income under section 1388(j)(1). We hold that it is not. Section references are to the Internal Revenue Code in effect for the years at issue. Rule references are to the Tax Court Rules of Practice and Procedure. The facts have been fully stipulated and are so found. The relevant facts are summarized below. Background A. Petitioner Petitioner's principal place of business was in New York City when it filed the petition in this case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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