Legal Opinion

Commissioner of Internal Revenue v. J. W. Gaddy and Ruth Gaddy, J. W. Gaddy and Ruth Gaddy v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided April 12, 1965No. 21247PublishedCited by 21 opinions

1Opinion of the Court

McRAE, District Judge.

This case comes to this Court for review of the Decision of the Tax Court.

Taxpayers J. W. Gaddy (Gaddy) and Ruth Gaddy, husband and wife, filed a joint income tax return for the calendar year 1957, using a cash method of accounting. The controversy centers around certain lease payments made to Gaddy by El Paso Natural Gas Products Company (El Paso).

In June 1956, El Paso and Gaddy entered into an oral agreement whereby El Paso leased certain tank truck equipment from Gaddy at a rental rate which, when added to the operating and maintenance costs, would not exceed the…

2Cases cited5 opinions

  1. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  2. Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
  3. Healy v. CommissionerSupreme Court of the United States · 1953
  4. United States v. MerrillCourt of Appeals for the Ninth Circuit · 1954
  5. Bates Motor Transport Lines, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1952

3Cited by21 opinions

  1. Howard B. Quinn and Charlotte J. Quinn v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1975
  2. Hope v. CommissionerUnited States Tax Court · 1971
  3. Karl and Hilda Hope, in Nos. 71-1993, 71-1994 v. Commissioner of Internal Revenue, in No. 71-1995Court of Appeals for the Third Circuit · 1973
  4. Mais v. CommissionerUnited States Tax Court · 1968
  5. Buff v. CommissionerUnited States Tax Court · 1972

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