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Tax Lawyer, Vol. 58, No. 2 PATRONAGE-SOURCED INCOME: AN EXPANDING UNIVERSE 479 PATRONAGE-SOURCED INCOME: AN EXPANDING UNIVERSE Clayton S. Reynolds* I. INTRODUCTION For taxable cooperatives,1 the distinction between patronage and nonpatronagesouurce income is critical.2 Subsequent to the publication of Revenue Ruling 69-576,3 there has been a notable expansion of the types of income that have been determined to qualify as patronage-sourced (sometimes with the approval of the Service but, often, in...

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