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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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