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INDEPENDENT CO-OP MILK PRODUCERS v. COMMISSIONER

Docket No. 10791-78.

76 T.C. 1001 (1981)

INDEPENDENT COOPERATIVE MILK PRODUCERS ASSOCIATION, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 15, 1981.

Attorney(s) appearing for the Case

David M. Rosenberger, for the petitioner.

Beth L. Williams, for the respondent.

HALL, Judge:

Respondent determined deficiencies in petitioner's income tax of $10,622.26 for 1973 and $19,895.35 for 1974. The issue for decision is whether allocations of patronage dividends to certain of petitioner's members constituted "qualified written notices of allocation" as defined by section 1388(c).1

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly.

At the time...

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