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UNION EQUITY COOPERATIVE EXCHANGE v. COMMISSIONER

Docket No. 439-70.

58 T.C. 397 (1972)

UNION EQUITY COOPERATIVE EXCHANGE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 31, 1972.

Attorney(s) appearing for the Case

Frank Carter, for the petitioner.

Thomas J. Miller, for the respondent.

OPINION

FORRESTER, Judge:

Respondent has determined deficiencies in petitioner's income tax of $81,267.77 and $138,164.30 for the taxable years 1961 and 1963, respectively. Petitioner does not contest certain of the adjustments which respondent has made in petitioner's taxable income for the taxable year 1963. The questions we must resolve are: (1) Whether for the taxable year 1963 petitioner may charge dividends...

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