ANCHORAGE, AUG. 27 -- The Internal Revenue Service, in a case that could spell trouble for a number of major U.S. corporations, is set to disallow the sale of $60 million in tax losses from an Alaskan-native-owned corporation to cereal maker Quaker Oats Co.

The ruling is seen here as the first volley in a wider effort by the IRS to recover some of the more than $400 million in tax benefits purchased by profitable corporations from companies owned by Alaska's Indians, Eskimos and Aleuts.

The thrust of the IRS ruling, which is scheduled to be formally released next month, was confirmed last week by an official of Shee Atika Inc., the native-owned corporation whose activities are the subject of the ruling.

The ruling follows a lengthy audit of a complex transaction that tested the limits of a provision of the 1986 tax law that allowed Alaska's native-owned corporations to sell losses to other corporations in search of tax write-offs. Other sales of tax losses among companies were otherwise eliminated from the tax code by the so-called tax reform law of 1986.

"We think the IRS position is absolutely outrageous," said James Senna, Shee Atika's chief executive, who said his company intends to fight the ruling in court.

John Calhoun, Quaker Oats associate general counsel, said his company "fully expects to work with and fight with the Alaskans."

Among other U.S. corporations that bought net operation losses -- or NOLs as they are known -- from corporations owned by native Alaskans were Emerson Electric Co., Marriott Corp., Pillsbury Co., Winn-Dixie Stores Inc. and Drexel Burnham Lambert Inc., all of which rushed to buy tax losses in a frenzy of deal-making that followed the amendment's passage.

In Shee Atika's case, the tax loss was created by two huge timber sales to a corporation in which it held a 49 percent interest. Those 1987 sales created what Shee Atika claimed was a more than $155 million loss that was then purchased by Quaker Oats. Quaker Oats, in turn, was able to save about $60 million in its federal tax payments, most of which was funneled back to Shee Atika.

IRS officials, citing confidentiality laws, have declined to comment on the sale. The agency questions both the structure of the deal and the values that Shee Atika placed on its timber, according to Senna.

Senna said the IRS, as a result of its ruling, is now seeking to recoup $60 million, not from Quaker Oats, but from Shee Atika.

The $60 million assessment would wipe out the company's net worth, according to company documents. With interest and penalties, the company calculates the assessment could reach as much as $80 million.

The native corporations were created by a 1971 act of Congress that transferred nearly $1 billion in cash and 44 million acres of land to the companies in return for Alaska's Aleuts, Eskimos and Indians relinquishing land claims.

By 1986, some of the native corporations were quite profitable, while others were struggling to stay solvent. But through the magic of accountancy, both rich and poor found losses to sell -- losses that would cost the U.S. Treasury more than $400 million.

After news articles appeared detailing the extent of the tax breaks involved, the provision was eliminated entirely from the tax code by Congress in the spring of 1988. Rep. Dan Rostenkowski (D-Ill.), chairman of the House Ways and Means Committee, saidat the time that the provision had been abused by the use of "accounting manipulation."

"Unfortunately, it has come to my attention that creative investment bankers and others may have turned a legitimate policy enacted by Congress into a significant tax loophole," Rostenkowski said then.

Much of the money that profitable corporations paid for the losses has been placed in escrow accounts, pending an outcome of IRS audits, according to reviews of native corporations' annual reports.

Alaska-based IRS agents have been poring over native corporations' records for several years, often camping out in corporate offices for months on end.

Many of the deals are not facing major IRS opposition, according to some accountants, attorneys and others involved in setting up the sales.

"I am familiar with many transactions that have survived the audits," said Cabot Christianson, an Anchorage attorney involved in arranging some of the sales.

According to Christianson and others, some of the most intense scrutiny is being directed at southeastern Alaska native corporations with large holdings of timber land.

Under the terms of the 1971 act settling claims by Alaskan natives, more than 10 Southeast Alaska corporations selected prime federal timber lands as their compensation. These corporations took title to the land in the early 1980s when timber prices were high. The difference between the appraised value of the timber at the time it was transferred and the price for which it was sold years later allowed a number of native corporations to calculate net losses that totaled more than $1 billion, according to Pete Hogan, a Ketchikan accountant involved in some of the sales.

Shee Atika's deal was one of the largest of the Southeast timber sales, involving 23,000 acres of old-growth timber of Sitka spruce, hemlock and cedar.

The company said its timber was worth $177 million when it received title in 1982, and it was sold for $10 million in 1987 to a company called Atikon, in which Shee Atika held a 49 percent interest. That price appears to be "way low," said Pat Joensuu, a timber company executive who representes another Southeast Alaska corporation involved in timber sales at that time.

In an interview last spring, Bob Jackson, an IRS official in Anchorage, explained that sales of timber by native corporations that generate net operating losses would pass muster only as long as they are "an honest effort to dispose of property at a fair market value."

Senna said the deal was just that, an arms-length transaction. But the IRS, he said, alleges "that the sale was not valid for tax purposes."

The IRS also is attacking Shee Atika's original appraisal of the timber at $177 million. The IRS, Senna said, claims the timber was worth $67 million -- a figure he dismisses as "ridiculous."

Still, Shee Atika faces an expensive, uphill battle if it seeks to overturn the IRS ruling.

Quaker Oats officials say they are puzzled by the IRS's decision to assess most of the taxes against Shee Atika rather than their corporation, which avoided paying the taxes. But a company spokesman was noncommittal on whether Quaker Oats would help finance Shee Atika's court battle.

"We want to do everything we can to help them," said Quaker's Calhoun. "We also have to protect Quaker's shareholders. It's premature to speculate."

Meanwhile, some other native corporations are preparing to do battle with the IRS.

"Everybody is going to fight the valuation issue," said Hogan, the Ketchikan accountant who represents several of the native corporations.

"I don't know of anyone who's not going to be questioned. It's like anything else. They {the IRS} are going to pick the lower value {of the timber}. And we're going to pick the higher side. And we're going to argue about it for a while.