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BARNETTE v. COMMISSIONER OF INTERNAL REVENUE

No. 5945.

49 F.2d 265 (1931)

BARNETTE et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

April 21, 1931.

Attorney(s) appearing for the Case

Frank J. Looney, of Shreveport, La. (Frank J. Looney, of Shreveport, La., and Holland & Strong, of Washington, D. C., on the brief), for petitioners.

G. A. Youngquist, Asst. Atty. Gen., Sewall Key, Sp. Asst. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and E. Riley Campbell, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., and J. P. Jackson, Sp. Asst. to Atty. Gen. (G. A. Youngquist, Asst. Atty. Gen., Sewall Key and J. P. Jackson, Sp. Assts. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Nathan Gammon, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for respondent.

Before BRYAN, SIBLEY, and HUTCHESON, Circuit Judges.

SIBLEY, Circuit Judge.

This petition for review concerns the income taxes for 1921 of J. M. Foster and W. A. Wilkinson, and turns on oil royalty transactions had in partnership with F. J. Looney. The three claimed certain royalty interests in Louisiana oil lands under one title, and West, Goldstein & Walker claimed royalty interests in the same lands arising under an adverse title. The opposing claimants of title were engaged in litigation. The above-named claimants...

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