Priv. Ltr. Rul. 201022006 (Jan. 24, 2010)

(based on cooperative's bylaws and operating agreement, grain payments to members and other patrons eligible to share in patronage dividends are PURPIMs and for purposes of computing DPAD, co-ops QPAI and taxable income should be computed without regard to any deduction for any grain payments to members and patrons eligible to share in patronage dividends).