OKLAHOMA FARMERS UNION v. COMMISSIONER

Docket No. 4584-74.

68 T.C. 651 (1977)

OKLAHOMA STATE UNION OF THE FARMERS EDUCATIONAL AND COOPERATIVE UNION OF AMERICA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 1, 1977.


Attorney(s) appearing for the Case

Jon H. Trudgeon and Donald R. Philbin, for the petitioner.

Michael J. O'Brien, for the respondent.


IRWIN, Judge:

Respondent determined the following deficiencies in petitioner's Federal income tax:

                 Year                      Deficiency

                 1970 .............       $312,290.59
                 1971 .............         40,305.19

After a concession by petitioner regarding a short-term capital gain, the only issue remaining is whether petitioner was a mutual insurance company entitled to...

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