Affiliated Foods, Inc., A Corporation - Page 4




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                                  FINDINGS OF FACT                                    
               Some facts are stipulated and are so found.  The stipulation           
          of facts, with accompanying exhibits, is incorporated herein by             
          this reference.                                                             
          Petitioner                                                                  
               Petitioner is a wholesale food purchasing cooperative that             
          resells a variety of products to retail grocery stores in Texas,            
          New Mexico, Oklahoma, Kansas, Colorado, and Arizona.  At the time           
          the petition was filed, petitioner maintained its principal place           
          of business in Amarillo, Texas.  Petitioner was incorporated in             
          1946 under the cooperative laws of the State of Texas to increase           
          the bargaining power of member stores in their dealings with                
          vendors.1  As of the time of the trial, petitioner had more than            
          239 shareholder-patrons, who operated approximately 715 member              
          stores.  Petitioner does not own any interest in any member                 
          store.                                                                      
               Petitioner computes its taxable income using an accrual                
          method of accounting and pursuant to the provisions of part I               

               1  The parties have stipulated that the term “member stores”           
          refers to retail grocery stores that individually or as a group             
          of related and associated retail grocery stores purchase food and           
          other consumer products from or through petitioner and that are             
          members of, or shareholders in, petitioner’s cooperative system.            
          They have further stipulated that the term “vendor” refers to               
          manufacturers or other producers of food and other products sold            
          to petitioner and member stores.  We shall adopt those locutions            
          for purposes of this report.                                                







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