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RUAN FINANCIAL CORP. v. U.S.

No. 91-3246.

976 F.2d 452 (1992)

RUAN FINANCIAL CORPORATION, Ruan Transport Corporation, Appellees, v. UNITED STATES of America, Appellant.

United States Court of Appeals, Eighth Circuit.

Decided September 29, 1992.

Attorney(s) appearing for the Case

Seth O. Heald, Washington, D.C., argued (Shirley D. Peterson, Gary R. Allen, Robert S. Pomerance, on the brief), for appellant.

Mark McCormick, Des Moines, Iowa, argued (Keith Martin, Washington, D.C., on the brief), for appellees.

Before JOHN R. GIBSON, BEAM, and MORRIS SHEPPARD ARNOLD, Circuit Judges.

JOHN R. GIBSON, Circuit Judge.

The question before us is whether Ruan Financial Corporation and Ruan Transport Corporation engaged in rebuilding and thus "manufacture" of highway tractors and was thereby subject to manufacturing excise taxes under 26 U.S.C. § 4051 (1988) and 26 U.S.C. § 4061(a)(1) (1982) (repealed 1984). The district court1 held that Ruan's reconditioning activities...

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