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GOLDEN ROD FARMS, INC. v. UNITED STATES

Civ. No. 82-HM-5721-NE.

652 F.Supp. 972 (1986)

GOLDEN ROD FARMS, INC., Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Alabama, Northeastern Division.

December 31, 1986.

Attorney(s) appearing for the Case

Stephen P. Parsons, Stoppel, Caldwell and Heggie, P.C., Chattanooga, Tenn., John C. Mooney, Wagner and Myers, Knoxville, Tenn., Jack Livingston, Gerald R. Paulk, Livingston, Porter & Paulk, P.C., Scottsboro, Ala., for plaintiff.

Frank M. Donaldson, U.S. Atty., Caryl P. Privett, Asst. U.S. Atty., Birmingham, Ala., Curtis L. Muncy, Helen M. Lokey, Dept. of Justice, Tax. Div., Washington, D.C., for defendant.

MEMORANDUM OF DECISION

HALTOM, District Judge.

The above entitled civil action presents the issue of whether substantial prepayments made by a corporate farmer taxpayer near the end of certain of its tax years for chicken feed or feed ingredients to be delivered and used in the taxpayer's broiler grow out operation in the year following purchase constituted nondeductible deposits in the tax years made rather than ordinary and necessary business expenses...

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