COOPERATIVE AGRICULTURE IN FLORIDA 109

operative associations. Section 5 of this Act reads as
follows.
 Persons engaged, as original producers of agricultural
products, such as farmers, planters, ranchmen, dairymen,
nut or fruit growers, acting together in association, cor-
porate or otherwise, in collectively processing, preparing
for market, handling, and marketing in interstate and/or
foreign commerce such products of persons so engaged,
may acquire, exchange, interpret, and disseminate past,
present, and prospective crop, market, statistical, eco-
nomic, and other similar formation by direct exchange
between such persons, and/or such associations or fed-
erations thereof, and/or by and through a common agent
created or selected by them.
 It is clear by this Act that Congress recognizes co-
operative business organization to be a legitimate activi-
ty to be engaged m by farmers, and reflects the intention
of giving them ample power to carry on such organiza-
tions effectively.
 Since cooperative business is conducted on a non-
profit basis, it has long been the contention of coopera-
tive associations that they should for this reason be ex-
empt from the payment of income taxes. This view has
been rather generally accepted by income tax officials,
who have laid down rulings which define the types of
business which shall be considered as non-profit. These
rulings were standardized in an amendment to the in-
come tax laws in 1938, and the following provisions
applying to cooperative associations were adopted'
 Section 101 (12) and (13) of the Internal Revenue Code
provides for the exemption of:

 (12) Farmers', fruit growers', or like associations or-
ganized and operated on a cooperative basis (a) for the
purpose of marketing the products of members or other
producers, and turning back to them the proceeds of
sales, less the necessary marketing expenses, on the basis