Farmland Industries, Inc. - Page 76




                                       - 71 -                                         
                  The determination of whether income derived by a                    
             cooperative from a transaction that is directly related to               
             the cooperative enterprise and, thus, is patronage income                
             is a determination that is necessarily fact intensive.                   
             Certified Grocers of Cal., Ltd. v. Commissioner, 88 T.C.                 
             238, 244 (1987); Illinois Grain Corp. v. Commissioner, 87                
             T.C. 435, 459 (1986); Washington-Oregon Shippers Coop.,                  
             Inc. v. Commissioner, T.C. Memo. 1987-32.  In considering                
             the relatedness of the income-producing transaction to the               
             cooperative enterprise, it is important to focus on the                  
             “totality of the circumstances” and to view the business                 
             environment to which the income-producing transaction is                 
             related and not to view the transaction so narrowly "as to               
             limit it only to its income-generating characteristic when               
             such a characterization is not consistent with the actual                
             activity."  Cotter & Co. v. United States, supra at 1106-                
             1107; Dundee Citrus Growers Association v. Commissioner,                 
             T.C. Memo. 1991-487.                                                     
                  The “directly related” test applied by the courts is                
             traceable to published rulings issued by the Commissioner,               
             such as Rev. Rul. 69-576, 1969-2 C.B. 166, and Rev. Rul.                 
             74-160, 1974-1 C.B. 245, that interpreted patronage income               
             broadly.  See CF Indus., Inc. v. Commissioner, supra at                  
             105; Illinois Grain Corp. v. Commissioner, supra at 453;                 






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