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GILLIS v. UNITED STATES

No. 25207.

402 F.2d 501 (1968)

William S. GILLIS, and Loretta L. Gillis, Appellants, v. UNITED STATES of America, Appellee. UNITED STATES of America, Appellant, v. William S. GILLIS, and Loretta L. Gillis, Appellees.

United States Court of Appeals Fifth Circuit.

October 15, 1968.

Attorney(s) appearing for the Case

Albert E. Coneway, Harlingen, Tex., for appellants.

Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Atty., Tax Div., Harry Baum, Robert I. Waxman, Attys., Dept. of Justice, Washington, D. C., Morton L. Susman, U. S. Atty., James R. Gough, Asst. U. S. Atty., Houston, Tex., for the United States.

Before GOLDBERG and CLAYTON, Circuit Judges, and HANNAY, District Judge.

GOLDBERG, Circuit Judge:

This suit for the refund of federal income taxes plus interest for the calendar years 1957 and 1958 presents two separate issues involving Internal Revenue Service objections to items returned as accruals by a partnership. The first issue concerns objections to the partnership's taking as an accrued liability the estimated future sales losses in fulfilling its contractual obligations to export cotton under the regulations of the Commodity...

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