THE COMMODITY CREDIT CORPORATION

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THE COMMODITY CREDIT CORPORATION
DAVID FIKE GODFREY
INTRODUCTION
No factor other than the weather probably effects agricultural
prices more than the policies of the Commodity Credit Corporation.
The various loan policies of the CCC generally set a stable floor
under the world market price of a commodity and add some degree-'of
consistency to the gamble of farming.
Through manipulation of
storage stocks and the exports program the CCC can effectively influence the supply of a given commodity which will be available in
the market place at a given time.
By either holding commodities
or dumping them on the market the CCC can either depress or increase
the price which the processor, retailer and housewife will have
to pay for the commodity in question.
The operations of the CCC are big business.
In 1974 there
were $449,000,000 worth of commodities pledged for loans and the
CCC had an inventory of $89,000,000 worth of commodities to which
it held title.
In Texas alone the Corporation made loans on:
595,000 bales of cotton at a dollar value of $52,267,000; 6,011,000
pounds of grain sorgham for a value $6,045,000; and 2,801,000 pounds
of wheat for a loan value of $3,423,000.
They also made loans on
other commodities such as barley, corn, honey, oats, peanuts, rice,
and soybeans.
This paper will attempt to present a broad overview of all
2
of the different operations of the Commodity Credit Corporation.
It will not attempt to explore in depth anyone phase of CCC operations.
However a more detailed study of the cotton loan pro-
gram will be made as a representative of all loan programs.
This paper will also attempt to present some of the various
mechanical problems which will be encountered by the farmer, rancher,
or lawyer in dealing with the daily operations of the CCC.
HISTORICAL PERSPECTIVE
The idea for the Commodity Credit Corporation had its origin
in the Federal Farm Board created under the Agriculture Adjustment
Act of 1933.
The Farm Board attempted to regulate prices by direct
controls on acreage and production.
l
In United States
~. Butler
the Supreme Court struck down the Agriculture Adjustment Act as an
unconstitutional regulation of agriculture within the states.
The
court held that it was both an invasion of the reserved powers of
the states and a case of improper delegation of authority.2
With the AAA and Federal Farm Board dead, the United States
Department of Agriculture had to formulate a new method of regulating
agricultural prices.
In October 1933, Jesse Jones, a Texas banker,
set up the Commodity Credit Corporation to lend money to farmers
who agreed to take land out of production the following year.3
The
CCC was set up as an independent agency of the Federal Government,
though it obtained its financing from and was managed in close
3
affiliation with the Reconstruction Finance corporation.
4
since the loans were at a figure higher than t he market price,
they served as an ingenious form of price support.
loan dealt only with cotton.
~
The original
The loan rate on cotton was lO¢ per
pound and the average market price was about 8¢ or 9¢.
rate quickly set a floor on the domestic market.
The loan
The terms of the
loan required that all of the cotton placed in the loan would be
held for security.
The government thus effectively acquired control
of almost the entire supply of domestic cotton.
This cotton was
held off the market and its absence tended to relieve the depressing
effect of a market surplus.
6
In 1935 the USDA came up with a new program based on the Soil
Conservation Act of 1935.
The plan of the new program was to pay
farmers for taking land out of soil depleting
crops and putting it
J
into soil conserving crops.
Since the soil depleting crops (whea t,
corn, cotton, and tobacco) were also the leading surp lus crops,
such an approach could achieve indirectly s omewhat the same effects
in controlling production and increasing farm income that the AAA
had achieved directly.
Sinc~
farmers received their benefit payments
not for curtailing production but for restoring soil fertility, the
criticisrnslcveled against the AAA were not directed at the new
program.
7
4
PURPOSE AND POWERS
The Commodity Credit Corporation was created for:
the purpose of stabilizing, supporting, and
protecting farm income and prices, of assisting
in the maintenance of balanced and adequate
supplies of agricultural commodities, products
thereof, foods, feeds, and fibers (hereinafter
collectively referred to as "agricultural
commodities"), and of facilitating the orderly
distribution of agricultural commodities ••••
e
The CCC may sue or be sued but no attachment, injunction,
garnishment, or other similar process may be issued against the
Corporat1on or its property. 9
Original jurisdiction for any suit
involving the Corporation is in the federal district courts without regard to the amount in controversy.
10
The CCC has a right
of intervention in any suit, action, or proceeding in which it
has an interest.
There is a six year statute of limitations running
from the time the action accrued, for all actions against the CCC
except in· cases where there is a disability which tolls the statute.
In such instances the limitation period is three years from the
time the disability is removed.
are tried ·without a jury.12
ll
All actions against the Corporation
The Corporation has all rights, privileges,
and immunities of the United States with respect to priority of
payments regarding debts due from insolvent, deceased, or bankrupt
debtors. ll
Contracts by the CCC are not subject to state and local
regulatory laws to the extent that such contracts provide otherwise
or to the
~xtent
that such contracts are inconsistent with the local
5
or state laws or rules'.
1.4
The CCC may acquire its own storage
warehouses in areas in which it determines that the privately
.
owned warehouses are inadequate to meet the needs of the Corporat10n.
l~
The Corporation may borrow money to finance its operations
but at no time may the borrowed money exceed $14,500,000,000. 16
The Corporation is empowered to accept strategic and critical
materials .produced abroad in exchange for commodities held by the
CCC.
These materials are transferred to the department of defense
and the CCC is reimbursed by the Secretary of the Treasury for
the value of these materials.
17
The Corporation is specifically empowered to:
(1)
support the prices of agricultural commodities through loans,
purchases, payments, and other operations,
(2)
make available materials and facilities required in connection
with the production and marketing of agricultural commodities,
(3)
procure agricultural commodities for sale to other governmental
agencies, foreign governments, and domestic, foreign, or international
relief agencies, and to meet domestic agreements,
(4)
remove and dispose of or aid in the removal or disposition of
surplus agricultural commodities,
(5)
increase the domestic consumption of agricultural commodities
by expanding or aiding in the expansion of domestic markets or by
developing or aiding in the development of new and additional markets,
marketing facilities, and uses for such commodities, and
6
(6)
aid in the development of foreign markets for agricultural
commodities.
1S
OPERATIONS IN GENERAL
The
eee
is currently operating under the Agriculture and
Consumer Protection Act of 1973
the Act).
19
(hereinafter referred to as
Under this act .t he Secretary of Agriculture has broad
discretion in determininqhow to attain the general objective of
pr~ce
support.
In U.S. v. Swift & Co.,
20
a case interpreting the
Agriculture Act of 1949,21 the predecessor to the Agriculture and
Consumer Protection Act of 1973, a price support program for milk
and butter fat which had as its main objective the support of prices
received by farmers and producers was upheld even though incidental
benefits accrued to processors and manufacturers.
22
The CCC could
not justify any program which was not calculated to accomplish the
general objective of the statute
23
and the means chosen had to be
reasonable calculated to achieve those ends.
24
The Secretary has authority, without notice, hearing, or
approval of commodity producers to require identification of a
co~~odity
erations.
in a particular way as a condition of price support op25
Different grades, varieties and types of a commodity
must usually be identified prior to receipt of a loan.
The Secretary
also has the authority to reduce support rates for a particular
commodity or for different grades within the commodity group.
This
7
is permissible even though the reduced support rate results in an
increased support rate for another variety of the commodity so
long as the average rate of support continues to be the percentage
of parity provided for in the applicable act. 26
Stroud v. Benson
27
dealt with discount varieties of tobacco.
The loan program and parity percentage were originally based on
high quality varieties of tobacco which were very much in demand
in the export trade.
Producers began growing inferior varieties
of tobacco which could not be recognized by sight from the superior
brands.
The influx of these inferior varieties into CCC stocks,
the increase in loaned funds connected with these brands, and general
complaints from the export trade prompted the Secretary of Agriculture
to require identification of these inferior varieties.
The loan
rate for these inferior varieties was subsequently cut to one-half
that of the better quality variety.
Producers sought to enjoin the
Secretary from identifying the varieties of tobacco in question and
sought an injunction requiring him to maintain the price support at
90\ of parity.
The court held that the Secretary had the authority
to require identification of the discount varieties of tobacco as a
condition of price support
28
and that he had the authority to reduce
. f er10r
'
"
t h e support rates f or t h ese 1n
var1et1es
0 f to b acco. 29
The Secretary may also designate which privately owned warehouses are approved for storage of commodities covered by 'the loan.
30
8
Except in instances specifically covered by the code (which will
be discussed later) no commodity will be eligible for the loan
unless it is stored in a government approved warehouse.
In order
to obtain approval of the Secretary of Agriculture a warehouseman
must submit a financial statement which was prepared within 90
days of the date of application and continue submission of statements annually after approval.
(1)
(2)
(3)
He must have :
a license to store the commodity in question,
a net worth of at least $10,000,
sufficient operating funds to meet daily requirements,
(4)
corrected any deficiencies owed to the government, and
(5)
provided any bonds which are required by the
Secretary of Agriculture'
3l
These bonds are to equal a value of not less than 5\ of the value
of the estimated quantity of processed commodities in the warehouse.
The bond cannot be less than $5,000 nor need it be greater
than $100,000.
32
In some instances where the farmer has adequate storage
facilities located on the farm the Secretary will allow the farmer
to store the commodity for the government.
Convenience and ease
of administration are taken into consideration in determining
if the farmer will be allowed to store his own commodities.
Govern-
ment loans are provided to some farmers, to enable them to build---_
their own storage facilities when the existance of such facilities
would be advantageous to the government.
33
9
Another condition for receipt of the loan, which was previously
applicable was compliance with acreage allotments • 34
. . · A producer was
entitled to aid by price support if he was a "co-operator."
A co-
operator was a producer on whose farm the acreage planted to the
commodity did not knowingly exceed the farm acreage allotment.
35
Today a producer is not required to comply with any acreage allotments in order to be eligible for the loan.
He can enter his entire
crop of any given commodity into the loan without fear of a penalty
for surplus production.
36
One who receives cash rent for land is
not a "producer" of the commodity grown on
t.....e
fore not eligible for a cotton loan under it.
land, and is thereA landlord who tried
to get a loan on cotton that he had bought from his tenants was
found guilty of mail fraud in Richardson v. U.S.
37
.The landlord
bought the cotton from his tenants and then had samples of the
cotton graded at a marketing association that he controlled.
The
grades on the various samples were raised one or two grade levels
above their true value.
The landlord then sent the graded samples
to the COC for determination of the loan value.
He was convicted
of mail fraud because he fraudulently represented the cotton to be
his own produce and because he sent the fraudulently graded samples
to the CCC via the mail.
The courts have no right to question the acts of the designated
agencies in administering the policies of the CCC, in absence of
charges of fraud or bad faith, provided the agencies acted within
10
the framework of the Act and did not abuse their discretion.
38
The
Corporation may in the exercise of its discretion refuse to adminiater a program through the warehouses of a particular person.
£££~.
Worthington
39
In
the CCC refused'to deal with a warehouseman
who had previously managed a tobacco warehouse that had been suspended
~y
the CCC.
Other farmers and tobacco buyers had had difficulty in
dealing with the warehouseman and his reputation showed a general
lack of integrity.
The court held that the CCC did not abuse its
discretion in refusing to extend price supports to tobacco sold to
any tobacco auction warehouse or tobacco auction business in which
'1
"
d • 40
the wareh ouseman actLve
y partLcLpate
The CCC has authority to recover any purchases or payments
improperly made by the corporation.
41
The Corporation is also
authorized to withhold payments when there is:
(1) a serious breach of contract or a violation of the
individual program requirements,
(2) - evidence of criminal or civil fraud,
(3) prior difficulty in collecting payments due the CCC,
(4) doubt that the debtor will be able to pay the CCC
on an outstanding judgment,
(5) a judgment obtained, and
(6) a request by the Justice Department for withholding
of payment. 42
.
The CCC can also stop payment in any of the above Lnstances.
The CCC also has a right of set off against all debts owed
to the CCC or any other agency of the Federal Government.
priority of claims in a set off situation is:
(1)
the Commodity Credit Corporation,
44
The
43
11
(2)
Agriculture Stabilization and Conservation
Service,
(3) all other agencies of the United states
. Departrnent of Agriculture (in order of
filing) ,
(4) Internal Revenue Service, and
(5) other Federal Government agencies (in
order of filing) .45
In these set off situations a prior assignment of the producer's
claim to another party is disregarded and the claim is set off
Just as if the producer still held the claim. 46
Under eB14p a buyer in the ordinary course of business takes
free of any claim by the CCC, based on want of authority in the
seller to sell such goods, provided he gave value, was a good faith
- purchaser, and there was no notice of defective title in the seller.
The buyer must assert an affirmative defense and establish by a
preponderance of the evidence each of the facts necessary to attain
relief.
47'
-- -
In U.s. v. Kerr Gifford and Co.
4B
the court held that
this section "manifested a congressional intent to protect the
purchaser who has parted with his money and received the goods without knowledge of any defect in the seller's authority to sell.
49
Section 714M
provides for a $10,000 fine or five years
~n
prison or both for any false statement in connection with an act
or influencing any action of the CCC.
This provision covers any
overvaluation of a commodity, embezzlement, theft, or conversion.
LOAN PROGRAM
The CCC currently makes non-recourse loans on cotton,
50
.
gra~ns,
51
12
peanuts,
52
honey,
· 58
and moh a1r.
53
wool,
54
naval st6res,
55
oil seeds,
56
tobacco,
57
Generally the provisions and mechanics of each loan
program are somewhat similar.
The cotton loan program is represent-
ative of all loan programs and will be set forth in detail below.
Application for a loan on cotton must be filed in the county
ASCS office where the cotton is grown.
59
The ASCS will then require
documents showing proof of ownership of the cotton On which the loan
is sought.
Typically loans are advanced on warehouse receipts for
warehouse storage loans and bills of lading for bills of lading loans.
After these documents are produced several other requirements must
be met before the loan is advanced:
(1)
60
The cotton must have been produced by a cooperator as defined
in the Agricultural Act of 1949 and this cooperator must be in
compliance with all acreage allotments and set aside requirements
applicable at that time. 61
(2)
The cotton must be of a grade and length which is specified for
the loan.
Ii?
The CCC will not accept cotton for the loan unless it
is specifically within a designated grade for which loans are made.
(3)
The cotton cannot be falsely packed, water packed, mix-packed,
reginned, or repacked.
(4)
63
The cotton must in fact be in existance and in good
cond~t~on.
Damaged cotton is not accepted to the loan.
(5)
The person seeking the loan must have a legal right to pledge
64
13
the cotton
65
and ' in conjunction with this requirement, the cotton
cannot be cotton which ha's been purchased by the prospective debtor 66
or cotton which was previously in the loan program and' has been
redeemed.
67
The CCC will not accept any bales of cotton into the loan which
weigh
le~s
than 325 pounds
·
69
pac k ag1ng
requ1rements.
approved warehouse.
70
68
and all bales must meet specific
All cotton'must be stored in a CCC
No provision was made for on the farm
storage of cotton bales.
The value of the loan is computed on the basis of the weights
shown on the warehouse receipts or the bills of lading.
7l
The CCC
will not make loans on the amount that any given bale exceeds 600
pounds. 72
The loan rete is set for one specific grade of cotton
by order of the Secretary.
The base grade is Strict Low Middling
1 1/16 and all other grades are either discounted or paid a premium
dependent on their variation from the base grade.
73
The cotton must .be classified as to staple and micronaire in
order to determine the grade.
USDA Board of Cotton Examiners.
The classification is done by the
If two or more classes of cotton
are submitted for the same loan, the loan is based on the 'lower of
the two grades.
74
The interest rate on the loan is variable and' is published
regularly . in the Federal Re9ister.
is 9.35\.76
75
The current interest rate
14
In order for cotton to enter the loan program it must be
free and clear of all leins.
If there are leins attached to the
cotton the producer must get a waiver from all lein holders,
laborers, landlords, and mortgagees, or obtain a subordination
agreement from them before the cotton will be accepted.
77
The loan matures automatically on the last day of the ninth
month following the month in which the loan was advanced or it is
payable upon demand at anytime prior to that date.
78
Upon maturity
and non-payment the CCC can sell, transfer, and deliver the cotton
or documents of title without notice to the producer or advertisement
or notice of the sale to the public.
79
Any overage in the sale price
ordinarily goes to the producer, however title rests in the CCC
immediately upon default and they are not required to pay any overage
if there is no sale.
80
The loan may be paid off at any time prior
to the maturity date but not after the CCC acquires title to the
collateral.
81
All approved warehouses are required to carr y insurance on the
commodities stored.
Liability for any damage or lo s s occurring
during the time a commodity is in the loan program falls primarily
on the warehouse.
The CCC can file claims against any liable party
for the amount of loss sustained.
The CCC credits the producer's
loan value (including interest and charges) with the value of any
recovery.
producer.
Any excess recovered over the loan value goes to the
82
15
MISCELLANEOUS PROGRAMS
The ccc administers several minor programs which are designed
to help in attaining the major goal of price support.' These programs
are not encountered by as large a segment of the agricultural population as are loan programs but they are significant for their OVerall effect on the economy.
In 1973 there was ,a bumper crop of grain in the United States
and approved storage facilities were not available for all of the
crop.
As a consequence the grain not in approved storage facilities
was not eligible for the nOn-recourse loan.
The CCC devised the
Distress Grain Loan Program which provides recourse loans for grains
stored in temporary facilities or on the ground.
The CCC is not
liable for any loss of quantity or quality under this program.
8~
The
!
recourse loan can be liquidated at maturity by:
(1)
(2)
(3)
repayment of the loan with interest at maturity,
transferring the grain into the non-recourse
program when facilities become available,
delivery of the grain to the CCC for credit at
the market price.
Since this is a recourse loan the producer is liable for any defiC1enC1es.
84
The CCC maintains several export programs to help maintain
competition between products produced in the U.S. and the World
Market.
The products covered in the general export program are
,
85 wheat and f 1 our, 86 fee d gra1ns,
'
87 and fl axsee d and l'1nseed
r1ce,
16
AA
oil. .
Export ·payments are designe<l to.
(1)
assure that the commodity produce<l in the U.S.
is generally competitive in world markets,
(2) avoid description of the world market price,
(3) aid the price support program by strengthenng
the domestic market price,
(4) re<luce the quantity of commodities which would
otherwise be taken into CCC stocks under its
price support program,
(5) promote the orderly liquidation of CCC stocks,
(6) fulfill the international obligations of the
Unite<l states'
89
Under this· program payments are made to approved exporters 90
SO
that they can afford to effectively compete with the world market
prices either in open world market operations or in programs covered
under Public Law 480.
91
The CCC also provides financing for impo:r~ing
nations under Public Law 480.
92
The CCC has one other export plan designed to encourage the
importation of quality breeding stock by underdeveloped countries.
In this program exporters sell hogs, beef and dairy cattle, and sheep
to the underdeveloped countries on a deferred payment plan.
CCC then purchases the exporters accounts receivable.
The
Bree<ling
animals sold under this plan must meet certain specifications as
to size, age, and quality.
93
The CCC has an emergency feed program which is
de s ~gne<l
to
provide fee<l grain at beneficial prices in designate<l areas where
there is a shortage of feed due to flood, drought, fire, hurricane,
storm, tornado, earthquake, disease, infestation or other catastrophe.
94
17
In order to be eligible to participate in the program the disaster
must have caused a serious loss of feed, including hay, pasture,
or range which normally would have been available to the owner's
livestock.
This loss must be one which causes an undue financial
burden upon the owner and requires him to purchase a quantity of
feed substantially more than he usually produces.
Individuals
who have a reputation of being wealthy as measured by local standards are automatically excluded from the program.
Once a producer
qualifies for the program he must repay all principal and interest
due on any feed grain that he has in the loan program.
After these
obligations are repayed, the CCC releases those feed grains which
are stored within a reasonable hauling distance of the producer's
livestock operation to him.
his livestock.
He is free to feed these grains to
After this grain is exhausted the producer may pur-
chase grain upon which the CCC holds title.
If the producer wants
to buy processed feeds from a feed dealer he may do so.
The CCC
will issue warrants to the grain dealer for the replacement of the
gra1n contained in the processed feed.
95
Finally the CCC administers a barter program in which exports
of U.S. agricultural commodities are used to finance procurement of
materials, equipment, goods and services required from foreign
sourceS by U.S. Government agencies and foreign procurement of
strategic and other materials for stockpiling.
18
Th", objectives of the program are:
(1)
to develop and expand foreign markets for U.S. farm products,
(2)
to improve the
(3)
to procure strategic materials to meet stockpiling goals,
(4)
to procure strategic materials in excess of stockpiling
u. s. balance of payments position,
goals where this is in the best interest of the
u.s.
when measured
against other alternatives such as taking foreign currencies in
payment.
96
APPENDIX
PARITY PRICING
Each loan rate for a commodity is based on a percentage of
parity which is set by statute or regulations.
A parity price is
one that will buy the same quantity of other products as it would
during some specified base period.
Parity prices provide a yard-
stick designed to represent a fair price for the commodities which
farmers produce in relation to the price of the commodities which
they buy.
Parity prices are determined by first computing the "parity
index."
This is an index number with the period 1910-1914 as a
base which includes the following cost items:
the general level
of prices for articles and services that farmers buy, wages of
hired farm labor, interest on farm indebtedness secured by farm
real estate and taxes on farm real estate.
index includes 335 items.
This part of the parity
This index is computed monthly by the
Bureau of Agricultural Economics and is published in the monthly
report entitled Agricultural Prices.
Next an index number of prices received by farmers is computed for all agricultural commodities.
subsidy payments.
This index includes any
The ratio of these two index numbers is referred
to as the "parity ratio."
It represents the per cent which agri-
20
cultural prices in general are of parity.
The next requirement is the computation of an "adjusted
base price." · This equals the average price received for a particular commodity for the lO-year period ending on the thirty-first
of December prior to the date of computation divided by the average
index number of prices received by farmers for all commodities for
the same lO year period.
The parity price for the particular com-
modity is then obtained by multiplying the adjusted base price by
the parity index.
This formula is designed to keep the same ratio between prices
received by farmers for all commodities and prices paid by farmers
as in the period 19l0-l9l4, but to permit price relationships
between individual commodities to be as they were in the most
recent lO years.
Parity prices for major items are published by
the Bureau of Agricultural Economics in the monthly issue of Agricultural Prices.
An·
example of parity computed on egg prices is set forth
below.
Average price received, ·Jan 1940 - Dec ·l949
~
Average index of prices received by farmers,
Jan 1940 - Dec 1949 ~
36.6¢ per doz
202% of 19l019l4 base period
250% of 19l019l4 average
21
Adjusted Base price - Average Price Received - Index of prices Received
18.1 ¢
Parity price of
45.2¢
.•
EggS
-
2.02
36.6
Adjusted Base ·Price X parity Index
18.1
X
2.50
Source:' Agricultural Pricing, Thomsen and Foote, 1952,
McGraw-Hill Book Company, Inc.
FOOTNOTES
1
Thomsen & Foote, Agricultural ·Pricing
355 (2nd ed. 1952 )
2297 U.S. 1 (1936)
3
Leuchtenburg,Franklin D. Roosevelt
4
the New
~
Thomsen & Foote, supra note 1 at 357.
5
Leuchtenburg, supra note 3
6schlesinger, The Coming
~~~ ~ 155 (1958)
7Schlesinger, The Politics
8
9
~
2f
Upheaval 504 (1966)
15 U.S.C •. § 714a (1964)
15 U. S . C. i 714b(c) (1964)
10 I d •
llId.
12 I d •
13
15 U.S.C. Ii 714b (d)
14
15
(1964)
15 U.S.C. Ii 714b (g) {1964)
15 U.S.C.
16
17
15 U.S.C.
19
21
714b(b) (1964)
15 U.S.C . Ii 714b (i) (1964)
18
20
§
§
714b(b)
(1964)
15 U.S.C. § 714c (1964)
7 U.S.C. § 1331 (1970)
152 F. Supp 738 (D.C. Md 1957)
7 U.S.C. E: 612(c) (1964)
74 (1963)
23
22
U.S. v. Swift & Co., 152 F. Supp. 738 (D.C. Md. 1957)
23 Id • at 752
24 Id •
25
Stroud v. Benson, 155 F. Supp. 482 (D.C. N.C. 1957)
26 Id •
27155 F. Supp. 482 (D.C. N.C. 1957)
28
Id. at 492
29 Id • at 491
30
31
32
.
Richardson v. U.S., 150 F.2d 58 (C.C.A. Tenn 1945)
7 C.F.R. I 14 2 3.2 ( 1974 )
7 C.F.R. § 1423.3 (1974)
33 7 C.F.R. § 1424 (1974)
34u• S • v. Appling, 239 F. Supp. 185 (D.C. 1965)
35 Id • at 191
36
37
Interv1ew w1th Walter Well, Manager Lubbock A.S.C.S.
150 F.2d 58 (C.C.A. Tenn 1945)
38
CCC v. Worthington, 263 F.2d 178 (C.A.N.C. 1959)
39
Id. at 180
40
Id.
41
U.S. v. Swift & Co. 152 F. Supp. 738 (D.C. Md. 1957)
42
7 C.F.R. § 1408.5 (1974)
43
7 C.F.R. Ai 1408.6 (1974)
44
7 .C.F.R. 6 1408.1 (1974)
45
7 C.F.R. § 1408.52 (1974)
24
46
47
7 C.F.R. § 1408.14
15 U.S.C. § 714
48
15 U.S.C. 3714 M (1964)
50
7 C.F.R. 11 1427 (1974)
51
7 C.F .R. 11 1421 (1974)
52
7 C.F.R.
53
55
!l
1422 (1974)
7 C.F.R. § 1434 (1974)
7 C.F.R. § 1472 (1974)
s
7 C.F. R. s 1438 (1974)
56
57
(1964)
136 F. Supp 771 (D.C. Idaho 1956)
49
54
o
(1974)
7 C.F.R. § 1443 (1974)
7 C.F.R. § 1464 (1974)
58
59
60
61
62
63
64
65
66
7 C.F.R.
!l
1468 (1974)
7 C.F.R. § 1427.3 (1974)
7 C.F. R. § 1427.6 (1974)
7 C.F.R.
!l
1427 . 7 (1974)
7 C.F.R.
!l
1427.6 (e)
(1974)
7 C.F.R. § 1427.6 (d)
(1974)
7 C.F.R.
ii
1427.6 (e)
(1974)
7 C.F.R. § 1427.6 (g)
(1974)
7 C.F.R. ~ 1427.6 (h)
(1974)
67 .
Id.
68
69
7 C. F. R. § 1427.6 (j )
(1974)
7 C.F.R. § 1427.6 (k)
(1974)
25
7°7 C.F.R. II 1427.8 (1974)
71
7 C.F.R. II 1427.9 (1974)
72
Id.
73
Id.
74
7
c. F. R. 1i
75
7 C.F.R.
76 '
§
1427.16 (1974)
1427.17 (1974)
Interview with Walter Wells, Manager Lubbock A.S . C. S .
77
7 C.F .R. § 1427.14 (1974)
78
7 C.F.R. § 1427.18 (1974)
79
Id.
80
Id.
81
7 C.F.R.
82
83
7 C.F.R. § 1473 (1974)
85
86
87
88
89
91
92
93
1427.25 (1974)
7 C.F.R. § 1427.24 (1974)
84
90
§
7 C.F.R.
§
1481 (1974)
7 C.F.R. § 1483 (1974)
7x C.F.R. Ii 1483 (1974)
7 C.F.R. . § 1484 (1974)
7
c. F. R. Ii
1486 (1974)
7 C.F.R. § 1481 (1974)
7 C.F.R. § 1483.110 (1974)
7 C.F.R.
5 1483.130 (1974)
Id.
7 C.F.R. § 1488 (1974)
26
94
7 C.F.R.
§
1475 (1974)
95 Id •
967 C.F.R. i 1495 (1974)
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