Priv. Ltr. Rul. 201216011 (Jan. 17, 2012)

(taxpayer, farmers' cooperative, marketed farm products by "agreement sales" which involve the co-op buying the products and reselling them with net profits accounted for on cooperative basis; such payments to patrons constitute PURPIMS and that co-op's DPAD to be computed without regard to any deduction for such payments).