Legal Opinion
Thomas W. Sowell and Lillian K. Sowell v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided April 25, 1962No. 19090PublishedCited by 10 opinions
1Opinion of the Court
WISDOM, Circuit Judge.
This is a man-bites-dog case. Here, taxpayers—not disinterestedly, of course —contend that they received income. The Commissioner denies that they did.
Thomas W. Sowell and his wife petition for review of an adverse decision by the Tax Court. 1 The prime question before us is whether the taxpayers constructively received the income from an oil lease in 1955,1956, and 1957. We hold that they did, and reverse the decision below.
The taxpayers and J. B. Sowell were the sole stockholders of the Riverside Production Company, which owned a seven-eighths working interest in an…
2Cases cited17 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- James v. United StatesSupreme Court of the United States · 1961
- Crane v. CommissionerSupreme Court of the United States · 1947
- Palmer v. BenderSupreme Court of the United States · 1932
- Burnet v. WellsSupreme Court of the United States · 1933
12 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Estate of Wallace P. Geiger, Deceased, Warren G. Dunkle, and Burnice I. Geiger v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1966
- Bryant v. CommissionerUnited States Tax Court · 1966
- A. G. Attebury Et Ux. v. United StatesCourt of Appeals for the Fifth Circuit · 1970
- Casa de La Jolla Park, Inc. v. CommissionerUnited States Tax Court · 1990
- A. L. Greer and Ruth E. Greer v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
5 more not listed; retrieve them via the Exa API.