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Association (a new name is to be later selected),
headquartered in Omaha, Neb.
The purpose of the consolidation plan was to serve
patrons better. Petitioner entered into the transaction
because it believed it could process its members’ soybeans
less expensively after the consolidation. As such, we find
that petitioner’s sale of the soybean facilities was
directly related to its patronage activities of producing
soybean products for its patrons.
Miscellaneous Section 1231 Assets
In 1983, petitioner disposed of approximately 525
miscellaneous depreciable assets used in its business.
These included tractors and other vehicles, livestock,
buildings, office furniture, and office equipment. The
assets in question were miscellaneous depreciable assets
used in the operation of petitioner’s business. Petitioner
disposed of the assets in the ordinary course of business
when they became obsolete or were no longer useful.
Petitioner’s sales of the miscellaneous section 1231
assets in this case is similar to the taxpayer’s sale of an
automobile in St. Louis Bank for Coops. v. United States,
224 Ct. Cl. 289, 624 F.2d 1041, 1050 (1980). In that case,
the taxpayer sold the automobile after it was fully
depreciated and purchased a new one. In holding that the
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