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WOOD v. COMMISSIONER OF INTERNAL REVENUE

No. 16090.

245 F.2d 888 (1957)

Nona B. WOOD, Owen A. Wood, Owen A. Wood and Nona B. Wood, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Owen A. WOOD and Nona B. Wood, Respondent.

United States Court of Appeals Fifth Circuit.

As Modified on Petition for Rehearing August 13, 1957.

Attorney(s) appearing for the Case

Wright Matthews, Dallas, Tex., Douglas W. McGregor, Houston, Tex., McGregor & Sewell, Houston, Tex., of counsel, for petitioner.

Meyer Rothwacks, A. F. Prescott, Lee A. Jackson, Attys., Dept. of Justice, John M. Morawski, Sp. Atty., Washington, D. C., Charles K. Rice, Asst. Atty. Gen., John Potts Barnes, Chief Counsel, Int. Rev. Serv., Washington, D. C., for respondent.

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

JONES, Circuit Judge.

This is a Federal income tax case. The taxpayers, Owen A. Wood and Nona B. Wood, are husband and wife and are residents of Texas. The tax years involved are 1945 through 1949. The taxpayers filed separate returns reporting community income for the years 1945 through 1947, and joint returns for 1948 and 1949. The taxpayers made land purchases in the western part of Florida of 5240 acres in 1943, 17,755 acres in 1944, 3437 acres in 1945, and 220...

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