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GARNAC GRAIN CO., INC. v. COMMISSIONER

Docket Nos. 35832-85, 8213-86, 7840-87, 7848-87.

62 T.C.M. 340 (1991)

T.C. Memo. 1991-363

Garnac Grain Co., Inc., et al. v. Commissioner.

United States Tax Court.

Filed August 6, 1991.

Attorney(s) appearing for the Case

William L. Bricker, Jr., Turner P. Smith, William B. Sherman, 101 Park Ave., New York, N.Y., for the petitioners. Anne Hintermeister and William H. Stoddard III, for the respondent. Wayne S. Kaplan, Thomas C. Durham, amicus curiae, for Cargill, Inc.

Memorandum Opinion

COHEN, Judge:

In our prior opinion, Garnac Grain Co. v. Commissioner [Dec. 46,693], 95 T.C. 7 (1990), we held that petitioners failed to meet the qualified export assets requirements of section 993(d) for the fiscal year ended January 31, 1975. We directed that decisions would be entered under Rule 155. (All section references are to the Internal Revenue Code as amended and in effect for the years...

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