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SUMMIT FARM, INC. v. COMMISSIONER

Docket No. 4875-79.

42 T.C.M. 1240 (1981)

T.C. Memo. 1981-556

Summit Farm, Inc. v. Commissioner.

United States Tax Court.

Filed September 28, 1981.

Attorney(s) appearing for the Case

James W. Littlefield and John M. Sullivan, First National Bank Bldg., St. Paul, Minn., for the petitioner. Stuart D. Gibson, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

By notice of deficiency dated January 18, 1979, respondent determined deficiencies in petitioner's Federal income taxes for the taxable years as follows:

  Tax year ended
       Dec. 31,         Deficiency

        1974 ...........  $12,566
        1975 ...........   24,368
        1976 ...........   34,383

The sole issue for our decision is whether petitioner Summit Farm...

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