This Article examines the application of the principles of income recognition and deferral to agricultural cooperatives and suggests a resolution to current inconsistencies in the law. Recent decisions have brought into question the ability of cooperative members to utilize both the ISA and deferred income agreements. This Article asserts that cooperative members can and should be able to take advantage of such options. Part I provides a general background on agricultural cooperatives and sets out the current legal framework for income recognition and deferral. Part II analyzes the current state of the law in regard to the treatment of cooperatives and identifies the features of that framework in need of clarification. The article concludes in Part III by identifying a clarified approach to income recognition that is consistent with both the language of the Code and the historical legislative treatment of cooperatives.
Sedo, Kathryn J. and Brenden, Mychal S.
"Fairness and Taxation: The Law of Deferred Income Recognition for the Members of Agricultural Cooperatives,"
Akron Tax Journal: Vol. 23
, Article 3.
Available at: https://ideaexchange.uakron.edu/akrontaxjournal/vol23/iss1/3