Ohio Farm Bureau Federation, Inc. - Page 5

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          common stock and also held some preferred shares.2  Petitioner              
          and Landmark shared common management until 1955.  During the               
          taxable year in issue, petitioner and Landmark shared office                
          space pursuant to a contract dated December 5, 1981, between                
          petitioner and Landmark.                                                    
               During the year in issue, local Landmarks were located                 
          throughout the State of Ohio, making Landmark the only regional             
          cooperative in Ohio that had local affiliates located throughout            
          the State.  Landmark, as the regional organization, dealt                   
          principally with petitioner, rather than with the county bureaus.           
          The local Landmarks worked with the county bureaus throughout the           
          State in a similar mutual and cooperative manner.  Most of the              
          farmers who were members of the county bureaus were also members            
          of the local Landmarks.                                                     
               On November 15, 1949, petitioner and Landmark (then known as           
          the Farm Bureau Cooperative Association, Inc.) entered into a               
          written service contract, whereby petitioner agreed to "perform             
          services on behalf of * * * [Landmark] in the fields of                     
          education, promotion, organization, publicity and public                    
          relations for the purpose of aiding in the purchasing and                   
          marketing activities of * * * [Landmark]."  Specifically,                   
          petitioner agreed to (1) disseminate information to Ohio farmers            


          2Petitioner continued to hold Landmark preferred shares                     
          until such shares were exchanged for Countrymark stock pursuant             
          to a merger in 1985.  See infra p. 9.                                       




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