Caldwell Sugars Co-op., Inc. v. United States

692 F. Supp. 659, 62 A.F.T.R.2d (RIA) 5943, 1988 U.S. Dist. LEXIS 9901, 1988 WL 90970
CourtDistrict Court, E.D. Louisiana
DecidedAugust 30, 1988
DocketCiv. A. No. 88-0336
StatusPublished

This text of 692 F. Supp. 659 (Caldwell Sugars Co-op., Inc. v. United States) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Caldwell Sugars Co-op., Inc. v. United States, 692 F. Supp. 659, 62 A.F.T.R.2d (RIA) 5943, 1988 U.S. Dist. LEXIS 9901, 1988 WL 90970 (E.D. La. 1988).

Opinion

OPINION

ARCENEAUX, District Judge.

This matter comes to the Court on a set of facts to which both parties have stipulated. The essence of those facts is stated below.

FACTS

Caldwell Sugars Co-op., Inc. (“Caldwell”) is a classic kind of corporate structure known as a cooperative; its members are producers of sugarcane who have joined together, as the law both permits and encourages, to manufacture, process, handle, market, buy, sell, and ship sugarcane and sugarcane products for their mutual benefit. As a nonexempt farmers’ cooperative corporation, Caldwell’s taxable income for its taxable year ended March 31, 1980, is determinable in accordance with the provisions of Subchapter T of the Internal Revenue Code of 1954, 26 U.S.C. §§ 1381-88 (“the Code”).

In December, 1978, the Commodity Credit Corporation (“CCC”), a federal agency, made nonrecourse loans to Caldwell as part of the federal price support program. The sole collateral pledged as security for these loans was a quantity of raw cane sugar stored by Caldwell on its premises. The loans had an original maturity date of November 30, 1979. From the date the loan was granted until the original maturity date, Caldwell was responsible for the cost of storage of the sugar. However, on November 29, 1979, Acting Secretary of Agriculture Jim Williams announced that CCC loans on cane sugar were eligible under the “reseal” program for extensions of their maturity dates until June 30, 1980. By federal regulation, storage costs for the pledged raw sugar during the extended period were to be borne by the CCC.

Caldwell obtained an extension of the maturity date of its loans until June 30, 1980. By the close of its taxable year of March 31,1980, Caldwell had received from CCC storage credits in the amount of $82,-578.00 in return for its storage of the pledged raw sugar.

In its federal income tax return for its taxable year ended March 31, 1980, Caldwell reported as part of its total “patronage dividend” deduction the portion of the storage costs paid by CCC which represented the proportion Caldwell’s business done with its “members patrons” (i.e., producers of cane sugar who were members of the cooperative and who did business with the cooperative) bore to its overall business with both member and nonmember patrons. Because 87.555% of Caldwell’s overall business consisted of transactions with members patrons, Caldwell treated 87.555% (or $72,293) of the $82,568 as deductible income. After an examination of Caldwell’s federal income tax return, the Internal Revenue Service (“IRS”) disallowed the claimed deduction of $72,293 as a patronage dividend deduction. The IRS made a deficiency assessment, which Caldwell paid, and Caldwell instituted the present refund suit.

[661]*661LAW

Section 1382(b) of the Code provides that “patronage dividends” shall not be taken into account in determining the taxable income of a cooperative. Section 1388(a) defines patronage dividends to mean:

an amount paid to a patron by an organization to which part I of this subchapter applies—
(1) on the basis of quantity or value of business done with or for such patron.
(2) under an obligation of such organization to pay such amount, which obligation existed before the organization received the amount so paid, and
(3) which is determined by reference to the net earnings of the organization from business done with or for its patrons. Such term does not include any amount paid to a patron to the extent that (A) such amount is out of earnings from business done with or for other patrons to whom no amounts are paid, with respect to substantially identical transactions. (emphasis added)

Treas.Reg. 1.1382-3(c)(2) defines “income derived from source other than patronage” to include “incidental income derived from source not directly related to the marketing, purchasing, or service activities of the cooperative association.”

The IRS has twice addressed whether such payments from the CCC constitute income from “business done with or for such patron.” In Revenue Ruling 59-107, the IRS held that:

[W]hen, as part of the price support program, money is loaned to a farmer/producer on his warehouse receipt for grain stored in a nonexempt cooperative, storage charges paid by the Commodity Credit Corporation for the period prior to default are income allowable to members as patronage dividends and are excludable from the cooperative’s income if there was a pre-existing obligation to allocate such patronage income.
The storage charges paid by the Commodity Credit Corporation for the period following default constitutes income not derived from patronage, as the grain at that time belongs to the Commodity Credit Corporation ... In either case, allocations to the patron are taxable income to the patron.

In Revenue Ruling 70-25, the IRS concluded that payments by the CCC to a cooperative during the period of a loan extension, when title to the pledged commodity remains with the cooperative, should be treated as taxable income. The IRS noted that the CCC is solely liable for payment of storage charges during the extension period, and may not collect them from the producer. The IRS held that:

[T]he handling and storage charges paid to the cooperative association under the reseal program by the Commodity Credit Corporation for which it is solely liable is income of the cooperative association derived from business done with or for the United State or any of its agencies and is income not derived from patronage sources.

Caldwell contends that Revenue Ruling 70-25 is unsound and should be rejected by the Court. Caldwell has pointed to judicial decisions which appear to adopt a broader definition of patronage-sourced income than that espoused by the IRS. In Land O’Lakes, Inc. v. United States, 470 F.Supp. 238 (D.Minn.1979), dividends on stock required to be purchased by a nonexempt cooperative to obtain loans needed to facilitate the cooperative’s marketing and purchasing activities constituted patronage income.

In St. Louis Bank for Cooperatives v. United States, 624 F.2d 1041, 224 Ct.Cl. 289 (1980), the Court gave great weight to Treas.Reg. § 1.1382-3(c)(2) (quoted herein supra), and held that the following revenues of a cooperative consisting of financial institutions were patronage-sourced income: (1) interest on demand deposits in farm credit banks and loans to brokerage firms; (2) interest on federal bonds purchased to maintain liquidity; and (3) profit from the sale of an automobile used in the business of the cooperative. The Court based its holding in part on Revenue Ruling 75-228, which stated that income is patronage-based if it is “produced by a transaction directly connected with market[662]*662ing patrons’ products.” The Court rejected the government’s reliance on a supposedly more specific ruling, stating that the ruling did not apply the “directly related” test and was too conclusory to be given weight. St Louis Bank, 624 F.2d at 1051. Finally, the Court stated its view as to the type of transaction which is “directly related” with patronage business:

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Related

Land O'Lakes, Inc. v. United States
470 F. Supp. 238 (D. Minnesota, 1979)
St. Louis Bank for Cooperatives v. United States
624 F.2d 1041 (Court of Claims, 1980)

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692 F. Supp. 659, 62 A.F.T.R.2d (RIA) 5943, 1988 U.S. Dist. LEXIS 9901, 1988 WL 90970, Counsel Stack Legal Research, https://law.counselstack.com/opinion/caldwell-sugars-co-op-inc-v-united-states-laed-1988.