Description
Tax Lawyer, Vol. 56, No. 4 WHAT THEN TO DO WITH A NON-COOPERATIVE COOPERATIVE? 825 825 WHAT THEN TO DO WITH A NON-COOPERATIVE COOPERATIVE? Clayton S. Reynolds* I. INTRODUCTION This article examines the tax treatment that should be accorded an entity that, while cooperative in form, is not operating “in accordance with cooperative principles.” More particularly, this article seeks to determine whether such an entity may deduct (or exclude) patronage allocations that it makes to its patrons...

Advertisement