South Texas Rice Warehouse Co. v. Commissioner of Internal Revenue

RIVES, Circuit Judge:

This is a companion case to Davant v. Commissioner of Internal Revenue, 366 F.2d 874 (5 Cir. 1966). While this case and Davant contain certain common issues of fact, they each involve distinct questions of law. For that reason we have elected to write separate opinions. The Tax Court held that the Commissioner did not abuse the discretion conferred by section 482 1 when he reallocated certain income between South Texas Rice Warehouse Company, 2 the petitioner in this case, and a partnership formed for the purpose of operating the assets of Warehouse. 43 T.C. 540 (1965).…