- 2 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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