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FARMERS COOPERATIVE CO. v. COMMISSIONER

Docket No. 15643-82.

89 T.C. 682 (1987)

FARMERS COOPERATIVE COMPANY (SUCESSOR-IN-NAME TO FARMERS CO-OP OIL COMPANY), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 29, 1987.

Attorney(s) appearing for the Case

Richard S. Wheeler and Stanley W. Rosenkranz, for the petitioner.

Ruud L. DuVall, for the respondent.

OPINION

GERBER, Judge:

This opinion is necessitated by a mandate, issued July 22, 1987, from the U.S. Court of Appeals for the Eighth Circuit affirming in part, reversing in part, and remanding for proceedings consistent with their opinion rendered regarding an appeal from our opinion in Farmers Cooperative Co. v. Commissioner, 85 T.C. 601 (1985) (Farmers I).

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