MAYFLOWER INVESTMENT CO. v. COMMISSIONER OF INT. REV.

No. 15953.

239 F.2d 624 (1956)

MAYFLOWER INVESTMENT COMPANY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

December 26, 1956.


Attorney(s) appearing for the Case

Sam G. Winstead, Robertson, Jackson, Payne, Lancaster & Walker, Dallas, Tex., for petitioner.

Carolyn R. Just, Atty., Dept. of Justice, Washington, D. C., Charles K. Rice, Acting Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, John Potts Barnes, Chief Counsel, John M. Morawski, Sp. Atty., I. R. S., Hilbert P. Zarky, Robert N. Anderson, Attys., Dept. of Justice, Washington, D. C., for respondent.

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


TUTTLE, Circuit Judge.

This petition for review from a decision of the Tax Court presents two questions: (1) Whether the court properly found that the sum of $12,300 received by petitioner in 1950 was interest instead of operating profit; and (2) Whether the failure of petitioner to file a personal holding company return for the years 1947 through 1950 was properly held by the Tax Court not to be due to reasonable cause and due to willful neglect and therefore warranted...

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