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CROWELL LAND & MIN. CORP. v. COMMISSIONER OF INT. REV.

No. 16016.

242 F.2d 864 (1957)

CROWELL LAND AND MINERAL CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

April 12, 1957.

Attorney(s) appearing for the Case

Richard L. Crowell, Alexandria, La., for petitioner.

David O. Walter, I. Henry Kutz, Lee A. Jackson, Attys., Dept. of Justice, Washington, D. C., Charles K. Rice, Asst. Atty. Gen., John Potts Barnes, Chief Counsel, Claude R. Marshall, Sp. Atty., Internal Revenue Service, Washington, D. C., for respondent.

Before HUTCHESON, Chief Judge, and CAMERON and JONES, Circuit Judges.

HUTCHESON, Chief Judge.

Crowell Land and Mineral Corporation petitions for a review of a decision of the Tax Court,1 three judges dissenting, sustaining the Commissioner in assessing against it for the year 1949 an income tax deficiency in the amount of $1,839.12. The majority concluded that Crowell's income in that year of $14,147.04, derived from sand and gravel removed from its lands pursuant to a written contract of sale by it as ...

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