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CO-OPERATIVE GRAIN & SUPPLY CO. v. C. I. R.

No. 19267.

407 F.2d 1158 (1969)

CO-OPERATIVE GRAIN & SUPPLY CO., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Eighth Circuit.

February 27, 1969.

Attorney(s) appearing for the Case

Robert C. Guenzel, Lincoln, Neb., for petitioner.

Karl Schmeidler, Atty., Dept. of Justice, Washington, D. C., for respondent, Mitchell Rogovin, Asst. Atty. Gen., and Lee A. Jackson, and Melva M. Graney, Attys., Dept. of Justice, Washington, D. C., on the brief.

L. James Harmanson, Jr., Washington, D. C., filed brief of amicus curiae, National Council of Farmer Cooperatives.

Before MATTHES, GIBSON and LAY, Circuit Judges.

MATTHES, Circuit Judge.

This case is before us on petition to review a decision of the Tax Court sustaining deficiencies and penalties assessed against Co-Operative Grain & Supply Co., (taxpayer) for income taxes for the years 1958, 1959, 1960 and 1961.

Taxpayer is a marketing and purchasing farmers' cooperative organization, having capital stock, dealing in grain and farm supplies. It is incorporated under Nebraska law and has its office and principal...

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