- 100 - a transaction that is directly related to petitioner’s cooperative enterprise and, therefore, is patronage income. Soybean Processing Facilities Part of petitioner’s patronage activities during the years in issue included purchasing soybeans from its patrons and processing them into soy oil and soy meal. Petitioner sold the soy oil to unrelated food processors for use in products such as margarine and processed the soy meal into livestock feed which it sold to its members. Petitioner sold its soybean processing facilities as part of a plan to consolidate its soybean processing operations with those of Boone Valley and Land O’Lakes. The circumstances surrounding petitioner’s sale of the soybean facilities are similar to those surrounding the sale of the Lamont gas plant. Petitioner sold its soybean facilities as part of a plan to make those operations more profitable for its patrons. The consolidation plan was completed in four steps: (1) Petitioner sold its soybean facilities to Boone Valley for $29.1 million; (2) petitioner purchased Boone Valley’s Eagle Grove, Iowa, feed mill for $10 million; (3) Boone Valley changed its name to Ag Processing, Inc.; and (4) the patrons of petitioner, Land O’Lakes, and the former Boone Valley received all of the equity interest in Ag Processing, Inc. The result ofPage: Previous 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 Next
Last modified: May 25, 2011