L. W. BROOKS, Jr. and Jane R. Brooks, et al., Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
United States Court of Appeals, Fifth Circuit.https://leagle.com/images/logo.png
April 8, 1970.
April 8, 1970.
Attorney(s) appearing for the Case
Buford P. Berry, J. W. Bullion, Dallas, Tex., for petitioners-appellants.
Johnnie M. Walters, Asst. Atty. Gen., Washington, D. C., Richard M. Hahn, Acting Chief Counsel, Internal Revenue Service, Washington, D. C., Lee A. Jackson, Grant W. Wiprud, William L. Goldman, Attys., U. S. Dept. of Justice, Washington, D. C., for respondent-appellee.
Before GEWIN, COLEMAN and DYER, Circuit Judges.
United States Court of Appeals, Fifth Circuit.
DYER, Circuit Judge.
In this appeal by the taxpayers1 from the decision of the Tax Court, the transactions involved are as simple as ABC2 but the tax consequences are not. The Tax Court held that the taxpayers, having purchased oil and gas working interests burdened by retained production payments, were required to capitalize, as additional costs of acquiring the properties, the expenses incurred by them allocable...
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