Farmland Industries, Inc. - Page 2




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                           Year Ended           Deficiency                            
                         August 31, 1982        $402,453                              
                         August 31, 1983        32,312,944                            
                         August 31, 1984        38,037,781                            
                         August 31, 1986        21,569                                

                  The sole issue for decision is whether the gains and                
             losses that petitioner, a nonexempt cooperative, realized                
             from the disposition of certain property should be                       
             classified as patronage income for purposes of subchapter                
             T of the Internal Revenue Code (sections 1381-1388).                     
             Unless stated otherwise, all section references are to the               
             Internal Revenue Code as in effect during the years in                   
             issue.  The gains and losses at issue are from the                       
             disposition of the stock of three corporations, Terra                    
             Resources, Inc., Seaway Pipeline, Inc., and Mex-Am Crude                 
             Corp., and from the disposition of certain property used                 
             in a trade or business, as defined by section 1231(b).                   


                                  FINDINGS OF FACT                                    
                  Some of the facts have been stipulated and are so                   
             found.  The amended stipulation of facts filed by the                    
             parties and the exhibits attached thereto are incorporated               
             herein by this reference.                                                
                  Petitioner is an agricultural cooperative organized                 
             under the laws of the State of Kansas.  References to                    






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