The C.M. Thibodaux Co., Ltd. v. United States

W. EUGENE DAVIS, Circuit Judge:

The C.M. Thibodaux, Co., Ltd. (Thibo-daux) appeals a summary judgment denying it recovery of federal income taxes and interest paid under protest. Thibodaux had transferred to its shareholders the right to receive bonuses and delay rentals from mineral leases on corporate property. The district court held that this transfer was an anticipatory assignment of Thibo-daux’s income and therefore the income from the bonuses and delay rentals was taxable to it. We find no error and affirm.

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Thibodaux is a corporation formed to purchase, hold, manage, and sell real…