Priv. Ltr. Rul. 201002009 (Oct. 1, 2009)

(grain payments made to member of farmers' cooperative and eligible non-member patrons are PURPIMs and for purposes of computing cooperative's Sec. 199 deduction, cooperative's QPAI and taxable income are to be computed without regard to any deduction for grain payments to members and eligible non-member patrons).

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