COMMISSIONER OF INTERNAL REVENUE v. CRICHTON

No. 9800.

122 F.2d 181 (1941)

COMMISSIONER OF INTERNAL REVENUE v. CRICHTON.

Circuit Court of Appeals, Fifth Circuit.

August 9, 1941.


Attorney(s) appearing for the Case

Richard H. Demuth, Sewall Key, and Warren F. Wattles, Sp. Assts. to the Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and Irving M. Tullar, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for petitioner.

Felix O. Rousset and Leo L. Dubourg, both of New Orleans, La., for respondent.

Before FOSTER, HUTCHESON, and HOLMES, Circuit Judges.


HUTCHESON, Circuit Judge.

In 1936, respondent and her three children, owning, in undivided interests, a tract of unimproved country land and an improved city lot, effected an exchange of interests. Her children transferred to respondent their undivided interest in the city lot. Respondent transferred to her children, as of equal value, an undivided 3/12 interest in the "oil, gas and other minerals, in, on and under, and that may be produced from" the country land...

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