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CWT FARMS, INC. v. COMMISSIONER

Docket Nos. 16365-80, 16367-80.

79 T.C. 1054 (1982)

CWT FARMS, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. CWT INTERNATIONAL, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 23, 1982.

Attorney(s) appearing for the Case

W. Woodrow Stewart, T. Treadwell Syfan, and Steven A. Cornelison, for the petitioners.

Bettie N. Ricca, for the respondent.

SUPPLEMENTAL OPINION

SIMPSON, Judge:

On July 19, 1982, this Court filed its findings of fact and opinion in this case (79 T.C. 86), in which we held that petitioner CWT International, Inc. (International), did not qualify as a domestic international sales corporation (DISC) for its taxable years ending in 1975, 1976, and 1977. Our holding was based on the conclusion that certain loans from International to petitioner...

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