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GROUP NO. 1 OIL CORP. v. BASS

No. 425.

283 U.S. 279 (1931)

GROUP NO. 1 OIL CORPORATION v. BASS, COLLECTOR OF INTERNAL REVENUE.

Supreme Court of United States.

Decided April 13, 1931.

Attorney(s) appearing for the Case

Messrs. Homer L. Bruce and James A. Baker for petitioner.

Solicitor General Thacher, with whom Assistant Attorney General Youngquist and Messrs. Sewall Key, Hayner N. Larson, Claude R. Branch, and John G. Remey, Special Assistants to the Attorney General, Erwin N. Griswold, and Clarence M. Charest, General Counsel, and Ottamar Hamele, Special Attorney, Bureau of Internal Revenue, were on the brief, for respondent.

Messrs. James V. Allred, Attorney General of Texas, and Fred Upchurch, Assistant Attorney General, by special leave of Court, filed a brief on behalf of the State of Texas, as amicus curiae.

MR. JUSTICE STONE delivered the opinion of the Court.

Petitioner brought suit in the District Court for Western Texas to recover federal income taxes alleged to have been illegally exacted for its fiscal years 1925 to 1928, inclusive. It set up that in those years it received income derived from the sale of oil and gas produced under leases to it by the State of Texas; that these leases were instrumentalities of the State for the development of its public domain;...

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