Camp Wolters Land Co. v. Commissioner of Internal Rev.

WALLER, Circuit Judge.

The taxpayer has admittedly been a Texas corporation since April 25, 1941, but the controversy here revolves chiefly around its status — corporate or otherwise — between that date and the middle of February in the same year at, and after, which time its in-corporators made contracts in the name of, and in behalf of, the taxpayer before its charter had been filed with the Secretary of State as required by Texas law. [Unless otherwise noted all events were in 1941.]

The facts found by the Tax Court may be summarized as follows:

Prior to January 1 the City of Mineral Wells,…