I’ll only cite to the last paragraph of Growmark Inc. & Subsidiaries, 2019 T. C. Memo. 161, filed 12/11/19, because it’s largely a repeat of AG Processing, as to which see my blogpost “A Hill of Beans,” 10/16/19.

Judge Paris: “The Court concludes that in accordance with this Court’s holding in AgProcessing, petitioner is not required to compute separate DPAD amounts for its patronage and nonpatronage activities.  Also in accordance with this Court’s holding in Ag Processing, petitioner must allocate its aggregately computed DPAD between its patronage and nonpatronage accounts.  Because the Schedule G allocation is done pursuant to subchapter T, not section 199, petitioner should allocate the aggregate DPAD on its Schedule G using the same method it used for its other Schedule G allocations.” 2019 T. C. Memo. 161, at p. 18.

If any of this makes sense to you, please accept my heartfelt condolences.

Oh, and Judge Paris will deal with Growmark’s COGS issues in a later opinion. I’m sure you’re all “hanging, breathless, on its fate,” as a far better writer than I put it.