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STEVENSON CO-PLY, INC. v. COMMISSIONER

Docket No. 8659-79.

76 T.C. 637 (1981)

STEVENSON CO-PLY, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 23, 1981.

Attorney(s) appearing for the Case

Wesley W. Kirtley, for the petitioner.

Leo A. Reinikka, Jr., for the respondent.

OPINION

TIETJENS, Judge:

Respondent determined a deficiency of $255,028 in petitioner's Federal income tax for 1973. The sole issue for decision is whether, for the purpose of computing the alternative tax under section 1201,1 a cooperative's section 631(a) gains are excludable or deductible to the extent that the cooperative distributes those gains to its stockholders through patronage dividends.

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