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COMMISSIONER OF INTERNAL REVENUE v. BROUILLARD

Nos. 888, 945, 951.

70 F.2d 154 (1934)

COMMISSIONER OF INTERNAL REVENUE v. BROUILLARD. SAME v. SHEPHERD SYNDICATE. SAME v. PRYOR & LOCKHART DEVELOPMENT CO.

Circuit Court of Appeals, Tenth Circuit.

April 4, 1934.

Attorney(s) appearing for the Case

Walter L. Barlow, of Washington, D. C. (Pat Malloy, Sewall Key, J. P. Jackson, and John H. McEvers, all of Washington, D. C., on the brief), for petitioner.

J. C. Campbell, of Charles City, Iowa, for respondent H. E. Brouillard.

George M. Morris, of Washington, D. C. (Allen H. Gardner, of Washington, D. C., on the brief), for respondents Shepherd Syndicate and Pryor & Lockhart Development Co.

Before LEWIS and BRATTON, Circuit Judges, and KENNEDY, District Judge.

BRATTON, Circuit Judge.

These cases involve the status of Iowa-Burk Syndicate, Shepherd Syndicate, and Pryor & Lockhart Development Company for income tax purposes. The material facts are:

No. 888.

During September, 1918, J. C. Campbell and J. M. Burns, of Charles City, Iowa, and R. E. Wade and H. E. Brouillard, of Wapanucka, Okl., acquired an oil and gas lease covering ten acres of land situated in the Burkburnett oil field in Texas, at a cost...

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