- 45 - 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.Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
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