- 75 - 624 F.2d at 1051-1052. As the court said in Twin County Grocers, Inc. v. United States, 2 Cl. Ct. 657, 662 (1983): A common thread runs through each of the cases and rulings above summarized. Although the income at issue is generated by transactions between nonexempt cooperatives and nonpatrons, it is deemed to be patronage sourced because those transactions facilitate the basic functions of the cooperative in some way other than simple money management or overall profitability. In applying the “directly related” standard, the courts have classified dividend income from a subsidiary of the cooperative as patronage income if the business of the subsidiary, out of which the dividends are paid, is reasonably related to the basic purpose of the cooperative. For example, in Linnton Plywood Association v. Commis- sioner, 410 F. Supp. 1100 (D. Or. 1976), the court held that dividends received by the taxpayer, a workers' cooperative, with respect to the capital stock it held in a glue manufacturing enterprise constituted patronage income. The taxpayer in that case was engaged in the manufacture and sale of plywood and plywood products. See id. To secure a reliable supply of glue, a material essential to the manufacture of plywood, the taxpayer and another cooperative organized a glue manufacturing enterprise. See id. Each cooperative owned 50 percent of the capital stock of the glue manufacturer. DuringPage: Previous 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 Next
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