REVENUE RULE 90-42

1990-1 C.B. 117, 1990-19 I.R.B. 4.

Internal Revenue Service
Revenue Ruling

COOPERATIVE ASSOCIATIONS; EXEMPTION FROM TAX; STOCK OWNERSHIP

Published: May 7, 1990

Section 521. - Exemption of Farmers' Cooperative from Tax, 26 CFR 1.521-1: Farmers' cooperative marketing and purchasing associations; requirements for exemption under section 521.
Cooperative associations; exemption from tax; stock ownership. Rev. Rul. 77- 440, 1977-2 C.B. 199, is revoked because it applies the 50-percent patronage test of Rev. Proc. 73-39, 1973-2 C.B. 502, that was revoked by Rev. Proc. 90- 29.

HOLDING

Rev. Rul. 77-440, 1977-2 C.B. 199, discussed situations where the 50-percent patronage test of Rev. Proc. 73-39, 1973-2 C.B. 502, applied. Because Rev. Proc. 73-39 was revoked by Rev. Proc. 90-29, page 22, this Bulletin, Rev. Rul. 77-440 is revoked.

EFFECT ON OTHER REVENUE RULINGS

Rev. Rul. 77-440 is revoked.

DRAFTING INFORMATION

The principal author of this revenue ruling is Paul Handleman of the Office of Assistant Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue ruling contact Mr. Handleman on (202) 377- 6349 (not a toll-free call).

Rev. Rul. 90-42, 1990-1 C.B. 117, 1990-19 I.R.B. 4.