Legal Opinion

Howell v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided February 8, 1944No. 10793PublishedCited by 9 opinions

1Opinion of the Court

WALLER, Circuit Judge.

The Commissioner of Internal Revenue contended, and the Tax Court found, that the petitioner’s deceased husband had not held an oil and gas lease for more than eighteen months prior to its sale and, therefore, was not entitled to the deduction allowable in computing long-term capital gains under Section 117 of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 117. This appeal results.

On October 6, 1937, one Ferguson en tered into a contract with Howell, who will be hereafter referred to as “the taxpayer”,' whereby the former agreed to execute and deliver an oil and…

2Cases cited3 opinions

  1. Helvering v. San Joaquin Fruit & Investment Co.Supreme Court of the United States · 1936
  2. McFeely v. CommissionerSupreme Court of the United States · 1935
  3. Norman v. WilsonCourt of Appeals of Texas · 1931

3Cited by9 opinions

  1. Northern Natural Gas Company v. GroundsDistrict Court, D. Kansas · 1968
  2. Paul v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
  3. Wyman v. CommissionerUnited States Tax Court · 1959
  4. Andrew Crispo Gallery v. CommissionerUnited States Tax Court · 1994
  5. Vaughan v. CommissionerUnited States Tax Court · 1961

4 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API