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LAND O'LAKES, INC. v. UNITED STATES

No. 3-71-Civ-49.

362 F.Supp. 1253 (1973)

LAND O'LAKES, INC., formerly Land O'Lakes Creameries, Inc., a Minnesota corporation, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. Minnesota, Third Division.

September 11, 1973.

Attorney(s) appearing for the Case

Doherty, Rumble & Butler, Harold Jordan, and Irving Clark, St. Paul, Minn., for plaintiff.

Robert G. Renner, U. S. Atty., Scott P. Crampton, Asst. Atty. Gen., Daniel J. Dinan, D. Patrick Mullarkey, and John A. Flanagan, Attys., Dept. of Justice, for defendant.

MEMORANDUM AND ORDER

DEVITT, Judge.

In this civil tax refund action to recover $254,978.74 of income tax and interest paid for the calendar year 1963, the principal issue is whether plaintiff violated § 521 of the Internal Revenue Code of 1954 and thus lost its qualification as a tax exempt organization. If the Court finds Land O'Lakes did not qualify as a tax exempt organization for the year 1963, then numerous secondary issues which relate to deductions...

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