Burk-Waggoner Oil Assn. v. Hopkins

The Burk-Waggoner Oil Association is an unincorporated joint stock .association like those described in Hecht v. Malley, 265 U. S. 144. It was organized in Texas and carried on its business there. Under the Revenue Act of 1918, Act of February 24, 1919, c. 18, 40 Stat. 1057, it was assessed as a corporation the sum of $561,279.20 for income and excess profits taxes for the year 1919. It paid the tax under protest in quarterly instalments, and after appropriate proceedings brought this suit in the federal district court for northern Texas against the Collector of Internal Revenue to recover…