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Year Ended Deficiency
August 31, 1982 $402,453
August 31, 1983 32,312,944
August 31, 1984 38,037,781
August 31, 1986 21,569
The sole issue for decision is whether the gains and
losses that petitioner, a nonexempt cooperative, realized
from the disposition of certain property should be
classified as patronage income for purposes of subchapter
T of the Internal Revenue Code (sections 1381-1388).
Unless stated otherwise, all section references are to the
Internal Revenue Code as in effect during the years in
issue. The gains and losses at issue are from the
disposition of the stock of three corporations, Terra
Resources, Inc., Seaway Pipeline, Inc., and Mex-Am Crude
Corp., and from the disposition of certain property used
in a trade or business, as defined by section 1231(b).
FINDINGS OF FACT
Some of the facts have been stipulated and are so
found. The amended stipulation of facts filed by the
parties and the exhibits attached thereto are incorporated
herein by this reference.
Petitioner is an agricultural cooperative organized
under the laws of the State of Kansas. References to
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Last modified: May 25, 2011