Priv. Ltr. Rul. 201024031 (Mar. 9, 2010)

(taxpayer, agricultural marketing cooperative, and payments made to members for grain pursuant to marketing agreements constituted PURPIMs within meaning of I.R.C. Sec. 1382(b)(3); for purposes of computing cooperative's I.R.C. Sec. 199 deduction, cooperative's QPAI and taxable income to be computed without regard to any deduction for such payments to members for grain pursuant to marketing agreements).