This court, in Bliss Dairy, Inc. v. United States, 645 F.2d 19 (9th Cir. 1981), affirmed the granting by the district court of the motion of plaintiff Bliss Dairy, Inc. for summary judgment.

The Supreme Court, on March 7, 1983, reversed the judgment of this court and remanded the case to this court for further proceedings in conformity with the opinion of that Court. Hillsboro National Bank v. Commissioner of Internal Revenue, - U.S. -, 103 S.Ct. 1134, 75 L.Ed.2d 130 (1983), rev’g Bliss Dairy, 645 F.2d at 19.

Upon due consideration, the judgment of the district court is reversed and the case is remanded for further proceedings in conformity with the mandate of the Supreme Court.

REVERSED AND REMANDED.