- 54 - During fiscal 1984, the Seaway Pipeline Co. sold its Freeport, Tex., to Cushing, Okla., crude oil pipeline. Seaway was organized in the mid- 70s to transport foreign crude oil from the Texas Gulf Coast to Midwest refineries. Farmland was a 12% owner of the Seaway facilities. With less need for foreign crude oil in the Midwest, the pipeline was no longer beneficial to Farmland’s refining operations. The sale of the pipeline was closed on May 1, 1984. Following the closing, Seaway's shareholders agreed to make short-term loans to Seaway of up to $15 million to cover operating expenses pending dissolution. Seaway was to repay these loans with the proceeds of the sale of the terminal facilities. In total, the shareholders lent Seaway $11,100,000. Petitioner's share of this loan was $1,332,000. The sale of terminal facilities closed in July and August 1984. Seaway ceased conducting business on August 31, 1984. Seaway used the proceeds from the sales of the pipeline and terminal facilities to repay its remaining debts to nonshareholders, the full amount of the short-term loans made by the shareholders, a portion of the shareholders' unapplied prepaid transportation charges, and the shareholders' respective shares of the cost of oil remaining in the pipeline at the time it was sold. On its 1984 Federal income tax return, petitioner reported an ordinary patronage loss from the SeawayPage: Previous 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 Next
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