The absence of any gifts of grain from the Hermiston facility does not detract from or alter its intended and exclusive use. The periodic rotation of the wheat through purchases and sales on the open market does not undercut this conclusion. There is no evidence that Plaintiff was in the grain business or that the profit motive was a material factor in the periodic purchase or sale of grain. Plaintiff, in storing the wheat, was, in a sense, a trustee. Lytle v Payette-Oregon Irr.
Wheat is a perishable commodity.
Plaintiff acted reasonably and consistent with its stated charitable purpose in rotating the grain by open market purchases and sales. School of Bible v. Mult. Maintaining that capacity to provide wheat advances the charitable goals of the church and meets a basic and fundamental religious tenet of the church. Dove Lewis Mem. Some might question the wisdom of Plaintiff's decision to spend millions of dollars on its grain storage program.