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.
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