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UNITED STATES v. WOOLSEY

No. 20427.

326 F.2d 287 (1963)

UNITED STATES of America, Appellant, v. R. T. and Gertrude WOOLSEY et al., Appellees.

United States Court of Appeals Fifth Circuit.

Rehearing Denied March 3, 1964.

Attorney(s) appearing for the Case

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Washington, D. C., Woodrow B. Seals, U. S. Atty., Houston, Tex., Michael Smith, David O. Walter, Attys., Dept. of Justice, Washington, D. C., John H. Baumgarten, Asst. U. S. Atty., for appellant.

John G. Heard, Houston, Tex., Vinson, Elkins, Weems & Searls, Houston, Tex., of counsel, for appellees.

Before HUTCHESON and GEWIN, Circuit Judges, and HOOPER, District Judge.

GEWIN, Circuit Judge.

This case involves Federal income taxes for the years 1955 through 1959. The Government has appealed from a final judgment of the U. S. District Court for the Southern District of Texas in favor of the taxpayers. The question presented is whether the amounts received by the taxpayers in consideration for the sale of their rights and interests in their partnership business which owned a management contract...

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