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schedule. The 1981 amendment was in effect during the taxable
year in issue.
Pursuant to the service contract, petitioner engaged in
various types of educational programs, which directly or
indirectly promoted cooperatives. For example, petitioner
conducted youth camps, where cooperatives and cooperative issues
were explained, and children were given the opportunity to
operate a small-scale cooperative. Petitioner also conducted
conferences for young couples dedicated to farming. These
conferences were jointly sponsored with Landmark and included
discussion about cooperatives. In addition, petitioner sponsored
advisory council meetings, in which small, voluntary groups of
farmers gathered to discuss farm topics. Petitioner would
suggest topics for discussion at these meetings, including
cooperative issues in general and assessment of the performance
of the local cooperative organizations.
Petitioner also engaged in various public relations
activities to promote cooperatives pursuant to the service
contract. For example, C. William Swank, petitioner’s executive
vice president and chief executive officer, and other staff
members of petitioner frequently spoke about cooperative issues
to farmer groups, university groups and classes, and service
clubs. Moreover, petitioner’s primary publication, the Buckeye
Farm News, included frequent editorial discussions about
cooperative ideas in general and about Landmark in particular.
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