Found this somewhat recent private letter ruling for how #coops should treat capital gains from assets used in the #coop's operations (such as the sale of a building) in terms of patronage.

The gist is that the patronage portion of the capital gain should be distributed on the basis of all #patronage allocated during the period that the property was owned and in operation.

https://www.taxnotes.com/research/federal/irs-private-rulings/letter-rulings-%2526-technical-advice/irs-rules-on-cooperative%E2%80%99s-sale-of-land-as-patronage-income/2cwx6

#cooperatives #cooplaw #cooptax #taxlaw