Myron A. Anderson v. Commissioner of Internal Revenue

AINSWORTH, Circuit Judge:

This is an appeal by Myron A. Anderson and his wife from an adverse Tax Court decision involving their federal income tax liability for the calendar year 1966. The sole question is whether taxpayers were entitled to an investment credit under Section 38 of the Internal Revenue Code of 1954 1 on oil and gas well equipment, where the funds used to purchase the equipment were acquired through the assignment of production payments, and were pledged to be used for that purpose.

Taxpayers owned undivided fractional interests in oil and gas leases in certain Texas counties.…