Campbell v. Big Spring Cowboy Reunion

RIVES, Circuit Judge.

The question to be decided on this appeal is whether the district court erred in holding that the taxpayer corporation, Big Spring Cowboy Reunion, which annually puts on a rodeo show at Big Spring, Texas, is exempt from taxation under the provisions of Section 101(1) of the Internal Revenue Code, 26 U.S.C. § 101(1), 1 as an agricultural organization. Such an organization is further described in Treasury Regulation 111, Sec. 29.101 (1)-1. 2 The district court found for the taxpayer with a succinct statement of the reasons for its decision. 3 Appellant insists that the find…