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SHAMROCK OIL & GAS CORPORATION v. C. I. R.

No. 21067.

346 F.2d 377 (1965)

The SHAMROCK OIL & GAS CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

Rehearing Denied July 9, 1965.

Attorney(s) appearing for the Case

W. M. Sutton, J. Avery Rush, Jr., Amarillo, Tex., Wright Matthews, Dallas, Tex., H. A. Berry, Amarillo, Tex., for petitioner on review, The Shamrock Oil and Gas Corp., Underwood, Wilson, Sutton, Heare & Berry, Amarillo, Tex., of counsel.

Michael Mulroney, Atty., Dept. of Justice, Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, R. P. Hertzog, Chief Counsel, I.R.S., Robert B. Alexander, Jr., Atty., I.R.S., Melva M. Graney, Atty., Dept. of Justice, Washington, D. C., for petitioner.

Before HUTCHESON, Circuit Judge, WHITAKER, Senior Judge, and RIVES, Circuit Judge.

HUTCHESON, Circuit Judge.

The petitioner here seeks reversal of two Tax Court decisions. The first determines petitioner's "gross income from the property" for the purposes of computing its depletion allowance for the fiscal years 1943 through 1954 with respect to natural gas produced by the petitioner and in which it owned an economic interest. The second concerns the tax treatment in the hands of petitioner of cash bonuses or initial payments paid by it for the...

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