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allocated in document amendment amounts retained applicable approved asso association was exempt beginning after December capital stock cash or merchandise cash or noncash cents per unit certificates of indebtedness computing Continental Oil Company cooperative association cost December 31 deduction derived from patronage document form Example excess profits tax exempt cooperative exempt from tax face amount following the close included income not derived Internal Revenue Code Internal Revenue Service justment letters of advice marketing and purchasing ment method of accounting negotiable instrument ninth month following noncash form operating loss paragraph patron the dollar patron's gross income patronage basis payments period of limitations pool prior to January provisions of section purchasing associations reasonable reserves rebates receipt Regulations 111 retain certificates retained as reasonable revolving fund certificates section 101 section 23 taken into account tax treatment tax under section taxable income taxable year beginning tion treatment under section valid obligation