Priv. Ltr. Rul. 201115009 (Jan. 10, 2011)

(grain payments made by cooperative to members and participating patrons are PURPIMs in accordance with 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 grain payments to members and participating patrons; I.R.C. Sec. 199 deductions that are passed through in a year in which cooperative incurs NOL will not affect amount of loss that cooperative can carry back or forward under I.R.C. Sec. 172).

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