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UNITED STATES v. FRAZELL

No. 20758.

335 F.2d 487 (1964)

UNITED STATES of America, Appellant, v. William D. FRAZELL and Martha T. Frazell, Appellees.

United States Court of Appeals Fifth Circuit.

August 5, 1964.

Attorney(s) appearing for the Case

Edward L. Shaheen, U. S. Atty., Shreveport, La., Louis F. Oberdorfer, Asst. Atty. Gen., Meyer Rothwacks, Harry Baum, Michael I. Smith, Lee A. Jackson, Attys., Dept. of Justice, Washington, D. C., for appellant, E. V. Boagni, Asst. U. S. Atty., of counsel.

W. Scott Wilkinson, Shreveport, La., for appellees.

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

TUTTLE, Chief Judge.

This is an appeal by the Government from a judgment in favor of the taxpayer. Frazell v. United States, W.D.La. 1963, 213 F.Supp. 457. As the largely undisputed facts are set out at length in the opinion of the district court, only a summary will be presented here. On February 9, 1951, William Frazell, a geologist, entered into a contract with the N. H. Wheless Oil Company, a partnership, and W. C. Woolf,...

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