Farmland Industries, Inc. - Page 50




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             total gain of $118,896,624 on its return for the taxable                 
             year ending August 31, 1983, $118,191,603 on its return for              
             the taxable year ending August 31, 1984, and $879,783 on                 
             its return for the taxable year ending August 31, 1986.                  
             The gain reported for fiscal year 1986 resulted from                     
             payments arising from various post-sale agreements between               
             petitioner and PLC.  Petitioner did not report any gain                  
             from the sale on its return for the taxable year ending                  
             August 31, 1985.                                                         
                  During the years in issue, petitioner maintained a                  
             total of approximately 20 allocation units for the purpose               
             of calculating patronage refunds.  From its accounting                   
             records of merchandise sold, petitioner determined the                   
             member sales and nonmember sales attributable to each                    
             allocation unit.  Petitioner defined a member sale as a                  
             sale of property or services to a person or entity                       
             entitled to receive patronage dividends.  This includes                  
             sales to members, associate members, and certain                         
             nonmembers who are entitled to receive patronage dividends               
             under contractual arrangements.  Petitioner defined a                    
             nonmember sale as a sale of property or services to a                    
             person or entity who is not entitled to receive patronage                
             dividends.                                                               








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