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FEDERAL LAND BANK ASSOCIATION v. COMMISSIONER

Docket Nos. 3457-76R, 3458-76R.

67 T.C. 29 (1976)

FEDERAL LAND BANK ASSOCIATION OF ASHEVILLE, NORTH CAROLINA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT MOUNTAIN PRODUCTION CREDIT ASSOCIATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 6, 1976.

Attorney(s) appearing for the Case

John S. Nolan and Gary G. Quintiere, for the petitioners.

Byron J. Furseth, for the respondent.

OPINION

WILES, Judge:

Petitioners adopted retirement plans in 1973. On or about May 20, 1974, applications for "determination letters" were filed with the Internal Revenue Service on petitioners' behalf. Petitioners, of course, wanted favorable determination letters in which the Internal Revenue Service would indicate that their plans qualified for special tax treatment. The Internal Revenue Service sent petitioners determination letters in February...

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