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WINN v. C. I. R.

No. 77-1939.

595 F.2d 1060 (1979)

E. H. WINN, Jr. and Betty Lee Jones Winn, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

May 23, 1979.

Attorney(s) appearing for the Case

Charles L. Brocato, Jackson, Miss., for petitioners-appellants.

Myron C. Baum, Acting Asst. Atty. Gen., Tax Div., Gilbert E. Andrews, Acting Chief, App. Section, U. S. Dept. of Justice, Charles L. Saunders, Acting Chief Counsel, Internal Revenue Service, Washington, D. C., Leon G. Wigrizer, Acting Chief Counsel, M. Carr Ferguson, Asst. Atty. Gen., Tax Div., Michael L. Paup, Aaron P. Rosenfeld, Attys., Dept. of Justice, Washington, D. C., for respondent-appellee.

Before THORNBERRY, CLARK and RONEY, Circuit Judges.

CHARLES CLARK, Circuit Judge:

This case presents two unrelated questions of construction of the federal income tax law. The first requires that we interpret the term "passive investment income" in order to determine whether a taxpayer qualified for small business corporation, or "Subchapter S," tax treatment under 26 U.S.C.A. § 1372 (Internal Revenue Code § 1372). The second involves examination of a claimed deduction for a charitable contribution under...

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