- 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”.Page: Previous 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 Next
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