- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011