W. EUGENE DAVIS, Circuit Judge:
The C.M. Thibodaux, Co., Ltd. (Thibodaux) appeals a summary judgment denying it recovery of federal income taxes and interest paid under protest. Thibodaux had transferred to its shareholders the right to receive bonuses and delay rentals from mineral leases on corporate property. The district court held that this transfer was an anticipatory assignment of Thibodaux's income and therefore the income from the bonuses and delay rentals...
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