- 48 - 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 benefitedPage: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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