Adkins Properties v. Commissioner

SIBLEY, Circuit Judge.

The Tax Court sustained assessments of taxes for the years 1936 to 1940 inclusive against the petitioner as an association, rejecting the contention that its returns as a mere distributive trust were correct.

In 1934 six members of the Adkins fam-' ily, through the legal services of one Wynne for a contingent fee of one-half the recovery, obtained judgment for a one-third interest in an oil lease of twenty acres of land in east Texas, on which three" producing oil wells had been drilled. The driller’s contract entitled him to certain oil payments from oil produced, and…