Co-op Partner in LLC Cannot Treat Partnership's Grain Purchases as the Co-op's PURPIM.

The taxpayer was a non-exempt cooperative and a partner in an LLC taxed as a partnership.  It wanted to treat the partnership's grain purchases as its per-unit retains paid in money (PURPIM) when the partnership bought grain from the taxpayer's current or former patrons.  The IRS determined that it could not.  Absent an agency relationship, the taxpayer did not satisfy the requirement that the grain be bought from the taxpayer's current or former patrons.  The fact that the LLC was taxed as a partnership and that the taxpayer's income from the partnership flowed through to its members was irrelevant because an LLC is not a cooperative and cannot ascribe to itself the attributes and ability of a member cooperative to issue PURPIMS.  CCM 20150801F (Apr. 22, 2014).

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