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  5. 791 F.Supp. 1450 (1992)
 

TOWE ANTIQUE FORD FOUNDATION v. I.R.S.

No. CV 89-141-BLG-JFB.

791 F.Supp. 1450 (1992)

TOWE ANTIQUE FORD FOUNDATION, a nonprofit Montana corporation, Plaintiff, v. INTERNAL REVENUE SERVICE, DEPARTMENT OF TREASURY, UNITED STATES of America, Defendant.

United States District Court, D. Montana, Billings Division.

March 5, 1992.

Attorney(s) appearing for the Case

Thomas E. Towe, Towe, Ball, Enright & Mackey, Gerald B. Murphy, Moulton Law Firm, Billings, Mont., for plaintiff.

Lorraine Gallinger, Asst. U.S. Atty., Keith Duet and Kirk Lusty, Trial Attys., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant.

FINDINGS OF FACT AND CONCLUSIONS OF LAW

BATTIN, Senior District Judge.

The above-captioned matter came for trial on October 15 and 16, 1991, before Senior United States District Judge James F. Battin, sitting without a jury. Thomas E. Towe and Gerald B. Murphy represented the Plaintiff, Towe Antique Ford Foundation (hereinafter "TAFF"). Kirk C. Lusty and Keith P. Duet, Trial Attorneys, United States Department of Justice, represented the United States of...

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