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FARMERS COOPERATIVE GRAIN CO. v. COMMISSIONER

Docket No. 68513.

39 T.C. 547 (1962)

FARMERS COOPERATIVE GRAIN COMPANY, A CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 18, 1962.

Attorney(s) appearing for the Case

Robert C. Guenzel, Esq., and James M. Stewart, Esq., for the petitioner.

Ivan L. Onnen, Esq., for the respondent.

MULRONEY, Judge:

The respondent determined deficiencies in the income tax of petitioner for the taxable years ended June 30, 1954, and June 30, 1955, in the respective amounts of $5,400.68 and $7,455.76.

The principal issue is whether income received for storage and handling of grain delivered to petitioner's elevator in satisfaction of Commodity Credit loans is to be considered nonpatron income and therefore not excludable from petitioner's gross income...

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