Farmland Industries, Inc. - Page 84




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             patronage income.  According to the court, by keeping                    
             short-term commercial paper the taxpayer was acting to                   
             retain its liquidity in order to prepay for goods at a                   
             discount and, thus, was “acting as any reasonable business               
             person”.  Id. at 1107.  The court compared the taxpayer’s                
             actions “to placing its funds in a bank account.”  See id.               
             The court also agreed with the taxpayer that rental income               
             from leasing temporarily excess warehouse space to tenants               
             should be classified as patronage income.  The court noted               
             that the warehouse space was rented only as part of the                  
             taxpayer’s “plan to expand its space over its then-existing              
             needs” and not as apart of a separate warehouse rental                   
             business.  Id. at 1109.  The court set forth the following               
             guiding principle for application of the directly related                
             test:                                                                    
                       We agree with the Claims Court that                            
                  Congress did not intend the term "with or for                       
                  patrons" to be "of unlimited scope, [so that]                       
                  all income produced by cooperatives that is                         
                  passed through to patrons would be, in essence,                     
                  income obtained for patrons, and would,                             
                  therefore, be considered patronage sourced."                        
                  Cotter, 6 Cl. Ct. at 227.  A cooperative cannot                     
                  merely "clothe its shareholders as patrons and                      
                  its corporate dividends as patronage payments"                      
                  and retain the benefits of Subchapter T.                            
                  Mississippi Valley, 408 F.2d at 835.  But                           
                  Subchapter T was also not enacted to require                        
                  that a cooperative acting for its patrons                           
                  function in an economically unreasonable manner                     
                  or penalize it for acting reasonably.  Consider-                    
                  ing the income-generating transaction in its                        
                  relation to all the activity undertaken to                          





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