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GREER v. C. I. R.

No. 20483.

334 F.2d 20 (1964)

A. L. GREER and Ruth E. Greer et al., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

July 8, 1964.

Attorney(s) appearing for the Case

Wentworth T. Durant, Ronald M. Mankoff, Dallas, Tex., Robert Edwin Davis, Dallas, Tex., Durant, Mankoff & Davis, Dallas, Tex., of counsel, for petitioners.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Crane C. Hauser, Chief Counsel, IRS, John M. Morawski, Atty., IRS, Melva M. Graney, Stephen B. Wolfberg, Crombie J. D. Garrett, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before BROWN, WISDOM and BELL, Circuit Judges.

BELL, Circuit Judge:

This matter arises out of a petition to review a Tax Court decision upholding deficiency assessments.1 The question presented turns on whether business expenses, admittedly deductible, accrued to petitioners as losses from a joint venture, or to a corporation, Oscura Company, Inc., the wholly owned subsidiary of another corporation, United Minerals, Inc., in which petitioners and their fellow venturers were the sole...

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