United States v. William D. Frazell and Martha T. Frazell

TUTTLE, Chief Judge.

This is an appeal by the Government from a judgment in favor of the taxpayer. Frazell v. United States, W.D.La. 1963, 213 F.Supp. 457. As the largely undisputed facts are set out at length in the opinion of the district court, only a summary will be presented here. On February 9, 1951, William Frazell, a geologist, entered into a contract with the N. H. Wheless Oil Company, a partnership, and W. C. Woolf, under which Frazell was to check certain areas to determine whether potentially productive oil and gas properties might be procured there. He was to recommend those…