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v. United States, 43 AFTR 2d 79-816, 79-1 USTC par. 9197
(D. Or. 1979); Linnton Plywood Association v. United
States, 410 F. Supp. 1100, 1108 (D. Or. 1976).
As appears from these cases, if the income at issue is
produced by a transaction which is directly related to
the cooperative enterprise, such that the transaction
facilitates the cooperative's marketing, purchasing or
service activities, then the income is deemed to be
patronage income. See, e.g., Cotter & Co. v. United
States, supra at 1106; Land O'Lakes, Inc. v. United States,
supra at 993; Certified Grocers of Cal., Ltd. v.
Commissioner, supra at 243; Illinois Grain Corp. v.
Commissioner, supra at 459. On the other hand, if the
income is derived from a transaction that has no integral
and necessary linkage to the cooperative enterprise, such
that it may fairly be said that the income is merely
incidental to the cooperative enterprise and does nothing
more than add to the overall profitability of the
cooperative, then the income is deemed to be nonpatronage
income. See, e.g., Cotter & Co. v. United States, supra at
1106; Land O'Lakes, Inc. v. United States, supra at 993;
Certified Grocers of Cal., Ltd. v. Commissioner, supra at
243; Illinois Grain Corp. v. Commissioner, supra at 459.
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