Farmland Industries, Inc. - Page 11




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             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 of                





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Last modified: May 25, 2011