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LOUISIANA LAND & EXP. CO. v. COMMISSIONER OF INT. REV.

No. 11878.

161 F.2d 842 (1947)

LOUISIANA LAND & EXPLORATION CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

May 19, 1947.

Attorney(s) appearing for the Case

James H. Yeatman, of Houston, Tex., for petitioner.

Newton K. Fox and Helen R. Carloss, Sp. Assts. to Atty. Gen., Sewall Key, Acting Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and Bernard D. Daniels, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before SIBLEY, HUTCHESON, and LEE, Circuit Judges.

LEE, Circuit Judge.

This case involves income taxes for the calendar years 1941 and 1942. We shall treat the question arising from the 1941 and that from the 1942 taxes separately since they are not interrelated.1

The 1941 tax issue: In 1928, the taxpayer entered into an oil and gas lease on the Paradis Oil Field with The Texas Company. In 1939, the taxpayer sued the McEnery heirs to quiet title against their adverse claims to...

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