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T.C. Memo. 1996-406 UNITED STATES TAX COURT THWAITES TERRACE HOUSE OWNERS CORP., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15777-94. Filed September 3, 1996. Terrence J. Dwyer, for petitioner.1 Andrew J. Mandell, for respondent. 1 Amici curiae briefs were filed by Mark A. Levy and Mayer Greenberg for Stewart Tenants Corp., and Joel E. Miller for the National Association of Housing Cooperatives, the Council of New York Cooperatives, and the Federation of New York Housing Cooperatives. 2 MEMORANDUM OPINION COLVIN, Judge: Respondent determined deficiencies in petitioner's Federal income tax of $8,117 for 1989 and $6,606 for 1990. The issues for decision are: 1. Whether petitioner, a housing cooperative under section 216, is subject to subchapter T (sections 1381-1388), aspetitioner contends, or is a membership organization under section 277, as respondent contends. We hold that petitioner is subject to subchapter T and is not subject to section 277. 2. Whether interest income earned by petitioner is patronage sourced income under section 1388(j)(1). We hold that it is not. Section references are to the Internal Revenue Code in effect for the years at issue. Rule references are to the Tax Court Rules of Practice and Procedure. The facts have been fully stipulated and are so found. The relevant facts are summarized below. Background A. Petitioner Petitioner's principal place of business was in New York City when it filed the petition in this case. 3 Petitioner was formed on September 2, 1983, under New York business corporation law. Petitioner uses the accrual method of accounting. Petitioner is a cooperative housing corporation under section 216(b)(1) and is not tax-exempt under section 501. Petitioner's certificate of incorporation was filed on August 30, 1983, and was amended on May 7, 1984. Petitioner's certificate of incorporation states in part that it was formed to provide homes for its stockholders by leasing apartments to them under proprietary leases that entitle them to live in the building. Petitioner's certificate of incorporation authorizes petitioner to issue 70,000 shares of one class of common stock at a par value of $1 each. Petitioner may make distributions to its shareholders only from its earnings and profits unless petitioner is completely or partially liquidated. Petitioner's bylaws did not authorize it to pay patronage dividends to its members in the years at issue. Petitioner's bylaws have no provisions relating to whether petitioner may distribute net earnings to its tenant-shareholders. Petitioner has no rules or regulations requiring it to distribute patronage dividends to its tenant-shareholders. Petitioner could use net earnings to reduce maintenance. Petitioner has never paid or allocated "net margins" (the excess of its operating revenues over its cost of operations) to its 4 patrons as patronage dividends. The record does not show if petitioner has ever had net margins. Petitioner's bylaws require petitioner to hold an annual meeting of the shareholders to elect directors and to conduct other business. The bylaws also provide for special meetings of the shareholders. Petitioner must give written notice of all shareholders' meetings to each shareholder.