District Court, D. Minnesota May 17, 1979, Civ. 3-71-49 (Land O'Lakes, Inc. v. United States)

MEMORANDUM & ORDER

DEVITT, Chief Judge.

This action is brought by plaintiff taxpayer, Land O’Lakes, a Minnesota cooperative, for refund of income taxes paid in 1963. Plaintiff is a “non-exempt cooperative,” a status which allows it to deduct “patronage dividends” from its gross earnings, subject to the restrictions of Subchapter T of the Internal Revenue Code.

See

26 U.S.C. §§ 1381-88 (1976).