Priv. Ltr. Rul. 201152006 (Sept. 21, 2011)

(agricultural cooperative's payments to members are PURPIMs under definition of I.R.C. Sec. 1382(b)(3); for cooperative's purpose of computing I.R.C. Sec. 199 deduction, cooperative's QPAI and taxable income computed without regard to any deduction for payments to members).

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