Priv. Ltr. Ruls. 200843016 (Jul. 21, 2008)

(amount of domestic production deduction (I.R.C. §199) for patronage distributions qualifying under I.R.C. §1382(b) that is paid to a Subchapter T cooperative in money must be computed at the cooperative level to prevent double counting; no distributions will eligible for I.R.C. §199 in the patron's hands).