SOWELL v. C. I. R.

No. 19090.

302 F.2d 177 (1962)

Thomas W. SOWELL and Lillian K. Sowell, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

April 25, 1962.

Attorney(s) appearing for the Case

Leland E. Fiske, Dallas, Tex., for petitioners.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, John B. Jones, Jr., Acting Asst. Atty. Gen., Melva M. Graney, Earl J. Silbert, Attys., Dept. of Justice, R. P. Hertzog, Acting Chief Counsel, John M. Morawski, Atty., I. R. S., Washington, D. C., for respondent.

Before BROWN, WISDOM, and BELL, Circuit Judges.

WISDOM, Circuit Judge.

This is a man-bites-dog case. Here, taxpayers — not disinterestedly, of course — contend that they received income. The Commissioner denies that they did.

Thomas W. Sowell and his wife petition for review of an adverse decision by the Tax Court.1 The prime question before us is whether the taxpayers constructively received the income from an oil lease in 1955, 1956, and 1957. We hold that they...

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