BAYOU VERRET LAND CO. INC. v. C. I. R.

No. 30347.

450 F.2d 850 (1971)

BAYOU VERRET LAND CO., Inc., et al., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Carlos and Jacqueline MARCELLO et al., Petitioners-Cross-Respondents, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Cross-Petitioner.

United States Court of Appeals, Fifth Circuit.

Rehearing Denied January 3, 1972.


Attorney(s) appearing for the Case

deQuincy V. Sutton, Meridian, Miss., Thomas J. Taylor, New Orleans, La., for petitioners.

Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks, Atty., Tax Div., U. S. Dept. of Justice, K. Martin Worthy, Chief Counsel, Eugene F. Colella, Atty., I. R. S., John M. Brant, Carleton D. Powell, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before GOLDBERG, GODBOLD and RONEY, Circuit Judges.


GODBOLD, Circuit Judge:

Consolidated for review in this court are five appeals from similarly consolidated decisions of the Tax Court on petitions to redetermine the Commissioner's assessments of deficiencies in the tax liabilities of a number of related Louisiana taxpayers.1 We affirm in part and reverse and remand in part.

I. Bayou Verret and Churchill Farms

During 1959-64 Bayou Verret Land Co., Inc., and Churchill...

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