United States Eighth Circuit

Given the agency relationship between a farming cooperative and plaintiff farmer and the voluntary nature of the deferred income at issue, the tax court did not err in finding that plaintiff received the value-added payments in the taxable years in which they were calculated, and were therefore not entitled to defer recognition of the payments as income until the next taxable year.

Appellate Information

• Decided 07/05/2006
• Published 07/05/2006

Judges

• ARNOLD, Circuit Judge., Before ARNOLD, JOHN R. GIBSON, and SMITH, Circuit Judges.

Court

• United States Eighth Circuit

Counsel

• For Appellant:
  
• Allan G. Bowen, argued, Minneapolis, MN, for appellants.


• For Appellees:
  
• Carol Barthel, argued, U.S. Department Office Justice, Tax Division, Washington, D.C., for appellee.