Farmland Industries, Inc. - Page 65




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             Petitioner reported the entire gain from the sale of the                 
             Lamont gas plant as ordinary patronage income.                           
                  In the subject notice of deficiency, respondent                     
             reclassifies the portion of the gain representing the                    
             amount realized in excess of cost basis, viz $12,852,544,                
             as nonpatronage capital gain under section 1231.                         
             Respondent does not take issue with petitioner's treatment               
             of the portion of the gain equal to depreciation recapture               
             under section 1245, $3,287,803, or the portion of the gain               
             equal to the amount of straight-line depreciation on                     
             section 1250 property, $81,328.  The notice of deficiency                
             describes this adjustment as follows:                                    

                  The section 1231 gain realized on the sale of                       
                  the Lamont, Oklahoma, gas plant must be                             
                  recognized as non-patronage capital gain and may                    
                  not be offset by patronage losses.  Accordingly,                    
                  your non-patronage capital gains are increased                      
                  by $12,852,544; the patronage ordinary income                       
                  you reported is decreased by $(11,640,781); and                     
                  the non-patronage ordinary income you reported                      
                  is decreased by $(1,211,763), in your fiscal                        
                  year ending August 31, 1984.                                        

             Soybean Processing Facilities                                            
                  Prior to August 1983, petitioner owned and operated                 
             three soybean processing facilities.  These facilities                   
             were located in Sergeant Bluff, Iowa, St. Joseph,                        
             Missouri, and Van Buren, Arkansas, and are collectively                  
             referred to herein as the soybean facilities.  Petitioner                





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