Norstam Veneers, Inc. A Kentucky Corporation - Page 2

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            Federal income tax of $27,844 and $31,888, respectively.  These                            
            cases (docket No. 27615-92 for 1988 and docket No. 608-93 for                              
            1990 and 1991) have been consolidated for purposes of trial,                               
            briefing, and opinion pursuant to Rule 141(a).                                             
                  The sole issue for decision is whether petitioner is                                 
            entitled to credits against income taxes pursuant to section 29                            
            for selling a qualified fuel to an unrelated person.  We hold                              
            that petitioner is not entitled to such credits.                                           
                  Unless otherwise indicated, all section references are to                            
            the Internal Revenue Code in effect for the years in issue, and                            
            all Rule references are to the Tax Court Rules of Practice and                             
            Procedure.                                                                                 
                                         FINDINGS OF FACT                                              
                  Some of the facts have been stipulated and are so found.                             
            The Stipulations of Facts are incorporated by this reference.                              
            Petitioner is a Kentucky corporation whose principal place of                              
            business was in Mauckport, Indiana, at the time the petitions in                           
            these cases were filed.                                                                    
            I.  The Veneer-Production Process                                                          
                  Petitioner is a wood veneer and lumber company incorporated                          
            in 1971.  From 1971-1979, petitioner took its logs to an                                   
            unrelated veneer mill, which converted them into veneer for a                              
            fee.  Petitioner then sold the veneer to its customers.  In 1979,                          
            petitioner purchased a wood-burning system that consisted of a                             






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