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WASHINGTON-OREGON SHIPPERS COOPERATIVE, INC. v. COMMISSIONER

Docket No. 21299-81.

52 T.C.M. 1406 (1987)

T.C. Memo. 1987-32

Washington-Oregon Shippers Cooperative, Inc. v. Commissioner.

United States Tax Court.

Filed January 14, 1987.

Attorney(s) appearing for the Case

Mark J. Rosenblum, 999 Third Ave., Seattle, Wash., for the petitioner. Henry Thomas Schafer, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined deficiencies in petitioner's Federal income tax in the amounts of $801 and $1,697 for the taxable years 1977 and 1978, respectively. After concessions, the issues are whether certain interest income was "from business done with or for *** patrons" within the meaning of section 1388(a)(3)1 and, if so, whether it was also income "derived *** from members...

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