Farmland Industries, Inc. - Page 53




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             made to petitioner.  At the time of these transactions,                  
             Terra owed petitioner a total of $150 million.  Petitioner               
             claimed a deduction pursuant to section 243 equal to the                 
             entire amount of the cash dividend received from Terra.                  
             The May 1983 dividend was not intended to offset an                      
             increase in the price of crude oil or natural gas.                       
             Because the dividend was excluded from petitioner's income               
             under section 243, it did not enter into petitioner's                    
             calculation of patronage income for its 1983 fiscal year.                
                  In July 1983, Terra paid another dividend, trans-                   
             ferring to petitioner its interest in the Axom Limited                   
             Partnership, which was valued at $4,797,890.  Petitioner                 
             received and reported as income an additional $161,573 in                
             dividends from Terra during its 1983 tax year.  It                       
             reported both of these dividends as patronage income.                    
             Petitioner reported the dividends it received with respect               
             to all other stock as nonpatronage income.                               
                  Petitioner did not sell its Terra stock because of                  
             any increase or decrease in the market price of crude oil                
             or natural gas, or any contemporaneous purchase of crude                 
             oil or natural gas on the open market.  Petitioner                       
             exercised its option to purchase crude oil produced by                   
             Terra several times between the date of the sale and the                 
             time of trial.  Although the call option has benefited                   






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