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DECISION OF THE SUPREME COURT OF THE RUSSIAN FEDERATION

of September 23, 1997 No. GKPI97-368

On behalf of the Russian Federation

The Supreme Court of the Russian Federation in structure:

the chairman - the judge of the Supreme Court of the Russian Federation               Yu.D.Redchenko,

in case of                                                                    Yu. V. Popova's secretary,

with participation                                                             of the prosecutor A. V. Fedotova

Having considered in proceeding in open court civil case according to the statement of Virgo private company for recognition by invalid subitems "and" Item 12 and Item 22 of the Instruction of the State Tax Administration of the Russian Federation of October 11, 1995 N39 "About Procedure for Calculation and Tax Discharge on Value Added" in the part limiting circle of export transactions which are exempted from the value added tax with export out of limits of the State Parties of the CIS - established:

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