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HALL v. C. I. R.

No. 18247.

294 F.2d 82 (1961)

Jesse E. HALL, Sr., and Rhoda O. Hall, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

July 19, 1961.

Attorney(s) appearing for the Case

Donald P. Moyers, John H. Conway, Jr., Tulsa, Okl., Martin, Logan, Moyers, Martin & Hull, Tulsa, Okl., of counsel, for petitioners.

Charles K. Rice, Asst. Atty. Gen., Hart H. Spiegel, Chief Counsel, Rollin H. Transue, Atty., I. R. S., Washington, D. C., Lee A. Jackson and Arthur I. Gould, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before RIVES, BROWN and WISDOM, Circuit Judges.

RIVES, Circuit Judge.

The facts in this tax deficiency case are fully and carefully stated in the opinion of the Tax Court reported at 32 T.C. 390, and may be here summarized with extreme brevity. Prior to 1947 petitioner Hall was engaged, in a small way, in manufacturing equipment he had designed for the cementing of oil wells. In March of 1947 the Gulf Oil Company, convinced of the merit of petitioner's products, placed an order with...

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