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DUNDEE CITRUS GROWERS ASSOCIATION v. COMMISSIONER

Docket No. 28006-88.

62 T.C.M. 879 (1991)

T.C. Memo. 1991-487

Dundee Citrus Growers Association v. Commissioner.

United States Tax Court.

Filed September 30, 1991.

Attorney(s) appearing for the Case

Donald E. Graham, 1401 New York Ave., Washington, D.C., for the petitioner. Mike E. Jorgensen, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes as follows:

Tax Year Ending                         Deficiency

  08/31/1985 .........................   $28,766
  08/31/1986 .........................    27,486

The sole issue for decision is whether interest earned by petitioner from its cash surplus constituted "patronage-sourced" income...

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