BUCKEYE COUNTRYMARK, INC. v. COMMISSIONER

Docket No. 29412-87.

103 T.C. 547 (1994)

BUCKEYE COUNTRYMARK, INC., SUCCESSOR TO FAYETTE LANDMARK, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 9, 1994.


Attorney(s) appearing for the Case

Arthur E. Bryan, Jr., George W. Benson, and David J. Duez, for petitioner.

James E. Kagy, for respondent.


WHALEN, Judge:

Respondent determined a deficiency of $26,272 in the Federal income tax of Fayette Landmark, Inc., for its fiscal year ending August 31, 1977. The sole issue for decision is whether section 277 applies to Fayette, a nonexempt cooperative subject to the provisions of subchapter T of the Internal Revenue Code (sections 1381-1388), and prohibits it from carrying back to fiscal year 1977 losses realized during fiscal year 1980 from transactions with...

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