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CAMPBELL v. BIG SPRING COWBOY REUNION

No. 14552.

210 F.2d 143 (1954)

CAMPBELL v. BIG SPRING COWBOY REUNION.

United States Court of Appeals Fifth Circuit.

February 12, 1954.

Attorney(s) appearing for the Case

H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Sp. Asst. to Atty. Gen., Louise Foster, Sp. Asst. to Atty. Gen., Washington, D. C., Cecelia H. Goetz, Sp. Asst. to Atty. Gen., Washington, D. C., Frank B. Potter, U. S. Atty., Midland, Tex., for appellant.

Grover Cunningham, Jr., Big Spring, Tex., for appellee.

Before HUTCHESON, Chief Judge, and BORAH and RIVES, Circuit Judges.

RIVES, Circuit Judge.

The question to be decided on this appeal is whether the district court erred in holding that the taxpayer corporation, Big Spring Cowboy Reunion, which annually puts on a rodeo show at Big Spring, Texas, is exempt from taxation under the provisions of Section 101(1) of the Internal Revenue Code, 26 U.S.C. § 101(1),1 as an agricultural organization. Such an organization is further described in Treasury Regulation...

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