Farmland Industries, Inc. - Page 61




                                       - 56 -                                         
                  The loss realized on the sale of the Seaway                         
                  Pipeline, Inc., stock must be recognized as                         
                  nonpatronage capital loss and may not be offset                     
                  by patronage income.  Accordingly, your non-                        
                  patronage capital losses are increased by                           
                  $(2,299,595); the patronage ordinary loss you                       
                  reported is decreased by $2,082,785; and the                        
                  nonpatronage ordinary loss you reported is                          
                  decreased by $216,810, in your fiscal year                          
                  ending August 31, 1984.                                             

             Mex-Am Crude Corp.                                                       
                  In an attempt to expand its access to crude oil from                
             sources outside the United States, petitioner became one                 
             of nine equal subscribers to the capital stock of the Mex-               
             Am Crude Corp. (Mex-Am).  All of these subscribers were                  
             companies that engaged in refining crude oil and required                
             reliable access to adequate supplies of crude.  Mex-Am was               
             incorporated on September 17, 1982.  It was organized to                 
             purchase oil in large volumes from Petroleos Mexicanos                   
             (PEMEX) on a collective basis for the benefit of its                     
             shareholders.  Each of Mex-Am's shareholders was obligated               
             to purchase a portion of the crude oil Mex-Am acquired                   
             from PEMEX.  This obligation terminated if at any time a                 
             shareholder surrendered its stock for no consideration.                  
                  Petitioner did not hold its Mex-Am stock for sale in                
             the ordinary course of business.  For financial reporting                
             purposes, petitioner reported its stock in Mex-Am in an                  
             account on its balance sheet labeled “Other Investments”.                






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