One of the concerns in a tax-free exchange to a new entity, particularly to a new entity such as a corporation that constitutes a separate taxpayer, is the array of midstream incorporation problems. Frequently, incorporation involves grain or other commodities that have been produced under the federal price and income support program for which a Commodity Credit Corporation (CCC) loan is to be obtained. The question is whether a CCC loan is obtainable by an entity other than the entity producing the commodity.



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