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ADOBE RESOURCES CORP. v. U.S.

No. 91-8342.

975 F.2d 1119 (1992)

ADOBE RESOURCES CORPORATION, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

October 9, 1992.

Attorney(s) appearing for the Case

Jon E. Fisher, Dept. of Justice, Tax Div., Dallas, Tex., Robert S. Pomerance, Gary R. Allen, Chief, Bruce R. Ellisen, Atty., Appellate Section, Dept. of Justice, Tax Div., Washington, D.C., for defendant-appellant.

T. John Ward, Brown, Maroney & Oaks Hartline, Houston, Tex., for plaintiff-appellee.

Before GARWOOD and DeMOSS, Circuit Judges, and DuPLANTIER, District Judge.

DeMOSS, Circuit Judge:

We have now read and considered the appellant's motion and brief on rehearing, the appellee's response in opposition to rehearing, and the appellant's reply to appellee's response and have concluded that our decision and opinion will stand as originally stated in this case. We recognize of course that private letter ruling 8901011 cited by appellee in its response could not be cited as authority for our original decision; (See 26 U.S...

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