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COMMISSIONER OF INTERNAL REV. v. WEST PRODUCTION CO.

No. 9781.

121 F.2d 9 (1941)

COMMISSIONER OF INTERNAL REVENUE v. WEST PRODUCTION CO. WEST PRODUCTION CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

July 7, 1941.

Attorney(s) appearing for the Case

Warren F. Wattles and Sewall Key, Sp. Assts. to the Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and Charles E. Lowery, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for petitioner.

Robert Ash, of Washington, D. C., and J. A. Platt, of Houston, Tex., for respondent.

Before FOSTER, HUTCHESON, and HOLMES, Circuit Judges.

HOLMES, Circuit Judge.

These petitions to review are from a judgment of the Board of Tax Appeals,1 and involve income taxes for the calendar year 1932. The questions presented arise from two distinct transactions, each of which will be discussed separately.

The Commissioner's appeal involves income taxes arising from the transfer to the Humble Oil & Refining Company of a one-half interest in twelve mineral leases upon lands...

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