Farmland Industries, Inc. - Page 80




                                       - 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.  During                   





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