Farmland Industries, Inc. - Page 5




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             bylaws require that net income from cooperative activities               
             be distributed to its patrons on a cooperative basis                     
             consistent with the provisions of subchapter T.                          
             Historically, petitioner’s overall approach has been to                  
             conduct business in the most economically advantageous                   
             fashion possible to maximize patronage dividends.                        
                  The following chart shows petitioner’s patronage and                
             nonpatronage income for tax years 1982 through 1986:                     

                                   NOL’s and    Patronage                             
              FYE    Patronage    Deductible   Income After Nonpatronage              
              8/31   Income        Dividend     Deductions  Income                    
              1982 ($107,448,343)     --      ($107,448,343) 1$13,013,621             
              1983  28,048,015   ($28,048,015)     --       1,202,216                 
              1984  104,087,552  2(103,945,724)141,828      14,778,795                
              1985 (17,151,510)       --      (17,151,510)    3(1,936,452)            
              1986  23,934,347   (24,361,501)      (427,154)   4(29,700,543)          

                  1 Petitioner reported nonpatronage taxable income of $12,416,037    
             on its original return.  The parties have stipulated that the correct    
             amount is $13,013,621.                                                   
                  2 The deduction consisted of a patronage dividend deduction of      
             $20,945,131, a net operating loss of $82,436,819 carried forward from    
             1982, and a patronage loss of $563,774 in respect of Farmland            
             Agriservices, a noncooperative subsidiary of petitioner, which           
             represented a carryover of net operating loss incurred by the company    
             before its liquidation into petitioner.                                  
                  3 Petitioner carried back the nonpatronage loss to its taxable      
             year ending August 31, 1982, and applied it against the nonpatronage     
             income for that year.                                                    
                  4 Portions of the NOL were carried back and applied against         
             nonpatronage income for taxable years ending August 31, 1983, and        
             1984.                                                                    

                  Petitioner’s consolidated operating results for fiscal              
             years 1984 through 1986 are as follows:                                  









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