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petitioner are to Farmland Industries, Inc. (Farmland), to
all predecessor corporations merged into Farmland, and to
all subsidiaries affiliated with Farmland, unless the
context suggests otherwise.
During the years in issue, petitioner reported income
and expenses on the basis of a fiscal year ending
August 31. Petitioner’s returns for fiscal years 1982 and
1983 were filed on Forms 1120, U.S. Corporation Income Tax
Return. Petitioner’s returns for fiscal years 1984 and
1986 were filed on Forms 990-C, Farmers’ Cooperative
Association Income Tax Return. Each of the returns was
filed with respondent’s service center in Kansas City,
Missouri. At the time its petition was filed in this case,
petitioner's principal place of business was Kansas City,
Missouri.
History and Organization of Petitioner
Farmland was founded in 1931 as the Cooperative Union
Oil Co. It was the successor to a Missouri cooperative
corporation called the Union Oil Co., which had been
founded in 1929 by Mr. Howard Cowden. Its corporate name
was changed to Consumer’s Cooperative Association in 1935,
and to Farmland in 1966.
Mr. Cowden served as Farmland’s president from the
time of its incorporation until 1961 and as a member of
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