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ILLINOIS GRAIN CORP. v. COMMISSIONER

Docket No. 6332-84.

87 T.C. 435 (1986)

ILLINOIS GRAIN CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 18, 1986.

Attorney(s) appearing for the Case

Arthur E. Bryan, James L. Malone III, and George W. Benson, for the petitioner.

Janet Engel, for the respondent.

KÖRNER, Judge:

For the short fiscal period June 1, 1979, through February 29, 1980, respondent determined a deficiency of $1,595,926 of corporate income tax against petitioner. After concessions by both sides, the issues which we must determine are (a) whether certain income earned by petitioner in the taxable period constituted income from patronage sources within the meaning of subchapter T,

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