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KINGFISHER COOPERATIVE ELEVATOR ASSOCIATION v. COMMISSIONER

Docket No. 5569-83.

84 T.C. 600 (1985)

KINGFISHER COOPERATIVE ELEVATOR ASSOCIATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 2, 1985.

Attorney(s) appearing for the Case

Arthur E. Bryan, Jr., James L. Malone III, Don E. Graham, and Gary C. Karch, for the petitioner.

Charles N. Woodward, Mary E. Speirer, and Gary L. Bloom, for the respondent.

COHEN, Judge:

Respondent determined a deficiency of $59,724.97 in petitioner's Federal income tax for the taxable year ended March 31, 1981, based on disallowance of part of the patronage dividend deduction1 claimed by petitioner, a farmers' cooperative subject to the provisions of subchapter T (secs. 1381 through 1388).2 The issue to be decided is the equitability of petitioner's allocation to its members...

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