William G. and Vivian Loomis - Page 3

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          The contracts do not provide for interest.  Nevertheless, Union             
          Elevator paid petitioners interest at a rate of 5 percent per               
          annum.  The following table contains the material terms of the              
          contracts in question:1                                                     

               Number        Net Payment       Interest          Total                
               5554A         $38,618.65        $449.67        $39,068.32              
               5644A         854.30            7.37           861.67                  
               5654A         2,210.50          18.77          2,229.27                
               5658A         6,636.61          56.37          6,692.98                
               5658A         12,534.33         106.46         12,640.79               
               5682A         11,790.75         92.06          11,882.81               
               5785A         7,880.40          42.10          7,922.50                
               5793A         37,925.87         187.03         38,112.90               
               5793A         17,869.47         88.12          17,957.59               
               5798A         19,800.50         94.93          19,895.43               
             Total           156,121.38       1,142.88        157,264.26              

          The wheat that petitioners sold pursuant to the contracts was               
          sold at the prevailing market price for wheat as of the date of             
          each contract.                                                              
               Union Elevator used grain settlement statements in deter-              
          mining the amount to be paid to petitioners.  The amount to be              
          paid consisted of the gross price agreed upon for the wheat, less           
          any grade discount or premiums, storage charges, and Washington             
          State Wheat Commission tax.  Also, petitioners pledged the                  



               1The amount shown for contract 5554A is net of the portion             
          pledged to secure a loan from Commodity Credit Corporation (CCC).           
          Respondent argues, and we agree, that, if we find for respondent,           
          then the full amount of this contract should be included in                 
          income, not reduced for the amount pledged to CCC.                          



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