SNEED v. COMMISSIONER OF INTERNAL REVENUE

Nos. 14855, 14871.

220 F.2d 313 (1955)

Brad Love SNEED, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. ESTATE of J. T. SNEED, Jr., Deceased, Elizabeth Sneed Pool and L. J. Haile, Executors, Respondents.

United States Court of Appeals, Fifth Circuit.

March 11, 1955.


Attorney(s) appearing for the Case

Geo. S. Atkinson and Tom B. Rhodes, Jr., Dallas, Tex., for Brad Love Sneed.

David O. Walter, Ellis N. Slack, William L. Norton, Jr. and A. F. Prescott, Sp. Assts. to Atty. Gen., H. Brian Holland, Asst. Atty. Gen., Daniel A. Taylor, Chief Counsel, Internal Revenue Service, Charles E. Lowery, Sp. Atty., Washington, D. C., for Commissioner of Internal Revenue.

Arthur Glover, Amarillo, Tex., for Sneed's Estate and others.

Before HOLMES, RIVES and TUTTLE, Circuit Judges.


HOLMES, Circuit Judge.

The relevant facts in these cases are the same, and both appeals may be disposed of in one opinion. The proceedings involve income taxes for the years 1940 and 1941. Jurisdiction of this court is invoked under Section 1141(a) of the Internal Revenue Code, as amended by Section 36 of the Act of June 25, 1948, 26 U.S.C.A. § 1141(a). The petition for review was filed on June 24, 1952. The Tax Court, 17 T.C. 1344

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