JAMES A. LEWIS ENGINEERING, INC. v. C. I. R.

No. 20533.

339 F.2d 706 (1964)

JAMES A. LEWIS ENGINEERING, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

December 15, 1964.


Attorney(s) appearing for the Case

William E. Collins, Rust E. Reid, Dallas, Tex., for petitioner, Thompson, Knight, Wright & Simmons, Dallas, Tex., of counsel.

Ralph A. Muoio, Atty., Dept. of Justice, Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Crane C. Hauser, Chief Counsel, Internal Revenue Service, Robert B. Alexander, Jr., Melva M. Graney, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before TUTTLE, Chief Judge, and BROWN and GEWIN, Circuit Judges.


TUTTLE, Chief Judge:

The petitioner here complains that the Tax Court erred in holding that they acquired their interest in certain oil producing property in 1957 rather than in some prior year and that such acquisition constituted taxable income to them.

The facts are not in dispute. Taxpayer was engaged in the business of petroleum engineering on a consulting basis. At the request of the operators of an oil and gas lease in Jefferson County, Oklahoma, known...

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