Court of Appeals for the Eighth Circuit July 1, 1987, 86-1831 (Farmers Cooperative Company (Successor-In-Name to Farmers Co-Op Oil Company) v. Commissioner of Internal Revenue)

HEANEY, Circuit Judge.

Farmers Cooperative Company (Farmers) appeals a decision of the tax court, 85 T.C. 601, that it did not qualify as an exempt cooperative association under Section 521 of the Internal Revenue Code, 26 U.S.C.