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JOHN PROVINCE #1 WELL v. C. I. R.

Nos. 14120-14129.

321 F.2d 840 (1963)

JOHN PROVENCE #1 WELL, Petitioner in 14,120, Hillis Well, Petitioner in No. 14,121, John B. Kline #1 Well, Petitioner in No. 14,122, G. R. Goode #1 Well, Petitioner in No. 14,123, Hoover Well, Petitioner in No. 14,124, Albert Donahoo #3 Well, Petitioner in No. 14,125, Albert Donahoo #2 Well, Petitioner in No. 14,126, Youngwood Coal Company Well, Petitioner in No. 14,127, Welty Unitized #2 Well, Petitioner in No. 14,128, J. O. Boyle and Winifred Boyle, Petitioners in No. 14,129 v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Third Circuit.

Decided July 3, 1963.

Rehearings Denied September 30, 1963.

Attorney(s) appearing for the Case

Ernest R. Dell, Pittsburgh, Pa., Reed, Smith, Shaw & McClay, Pittsburgh, Pa. (Joseph G. Robinson, Norman D. Keller, Pittsburgh, Pa., on the brief), for petitioners.

Frank I. Michelman, Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, I. Henry Kutz, Donald P. Horwitz, Attys., Department of Justice, Washington, D. C. on the brief), for respondent.

Before HASTIE, GANEY and SMITH, Circuit Judges.

HASTIE, Circuit Judge.

In each of these cases, the Tax Court has decided that an agreed business arrangement for the production and marketing of natural gas from a well, in which a number of persons held fractional working interests, was such as to make the enterprise an association taxable as a corporation within the meaning of section 3797(a) (3) of the Internal Revenue Code of 1939, ch. 2, 53 Stat. 469, and the corresponding section 7701(a) (3) of the 1954 Code...

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