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TATUM v. C. I. R.

No. 24361.

400 F.2d 242 (1968)

Clyde G. TATUM and Veta Rae Tatum, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

September 6, 1968.

Attorney(s) appearing for the Case

William H. Evans, Lubbock, Tex., for petitioners.

Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Harry Baum, Louis M. Kauder, Attys., Dept. of Justice, Lester R. Uretz, Chief Counsel, I.R.S., Richard P. Milloy, Atty., I.R.S., Washington, D. C., for respondent.

Before BELL, COLEMAN, and GODBOLD, Circuit Judges.

GODBOLD, Circuit Judge:

Petitioners are owners of farm land. They entered into verbal agreements with share-crop tenants under which the tenants agreed to pay as land rent fractional parts of the crops produced. In 1961 and 1962 petitioners made donations to charities of grain and cotton crops1 grown on the rented land by share-crop tenants and paid in kind as land rent. On their federal income...

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