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TAYLOR OIL & GAS CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 5856.

47 F.2d 108 (1931)

TAYLOR OIL & GAS CO. et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

February 26, 1931.

Attorney(s) appearing for the Case

George E. Shelley, of Austin, Tex., for petitioner.

G. A. Youngquist, Asst. Atty. Gen., C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Allin H. Pierce, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., and S. Dee Hanson, Sp. Asst. to Atty. Gen. (J. Louis Monarch and F. Edward Mitchell, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before BRYAN and FOSTER, Circuit Judges, and HUTCHESON, District Judge.

FOSTER, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals upholding a deficiency assessment of $34,398.83 against the Taylor Oil & Gas Company. 15 B. T. A. 609. There is no dispute as to the material facts, and it is conceded that, if the tax could be legally assessed against the company, the amount is correct.

The Taylor Oil & Gas Company, a Texas corporation, entered into negotiations with the Magnolia Petroleum Company...

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