DOWELL v. UNITED STATES

Nos. CA3-3521-C, CA3-3522-C, CA3-5474-C and CA3-5475-C.

370 F.Supp. 69 (1974)

Cam F. DOWELL, Jr., and Evelyn Dowell v. UNITED STATES of America (two cases). HILLCREST STATE BANK v. UNITED STATES of America (two cases).

United States District Court, N. D. Texas, Dallas Division.

January 30, 1974.


Attorney(s) appearing for the Case

Ethan B. Stroud, Robert W. Ryan, Jr., L. Vance Stanton, Richard D. Pullman, Stroud & Smith, Dallas, Tex., for plaintiffs.

Frank D. McCown, U. S. Atty., Martha Joe Stroud, Asst. U. S. Atty., Charles G. Barnett and William W. Guild, Tax Div., Dept. of Justice, for defendant.


MEMORANDUM OPINION

WILLIAM M. TAYLOR, Jr., Chief Judge.

Hillcrest State Bank of Dallas, Texas, and its president since 1956, Cam F. Dowell, Jr.,1 sued the United States for the refund of some $54,000.00 in federal income taxes.2

The key question in these consolidated cases, which were tried before the Court, is whether the Internal Revenue Service...

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