Marlis Carson with the National Council of Farmer Cooperatives has informed us of several recently-released IRS private letter rulings concerning cooperatives:

a)  Three rulings substantiate the position announced earlier by the Service (see E-Counters, July 17, 2008), that pooling cooperatives can add back "per-unit retains paid in money" when calculating their domestic production activities income deduction under Code sec. 199; PLR 200843015, PLR 200843016, and PLR 200843023.

b) A purchasing and distribution cooperative of retail stores was allowed to treat the gain realized on the sale of a warehouse as patronage-sourced when distributed to its patrons on the basis of patronage, PLR 200842011.

c) The application of a brine shrimp farmers' cooperative for Code sec. 521 tax status was denied because the Service determined brine shrimp harvesting was not a "farming" activity as defined in Code sec. 464(e)(1), PLR 200841038.

These rulings are all available at www.irs.gov in the "written determinations" section of the web site.