Legal Opinion

Jesse E. Hall, Sr., and Rhoda O. Hall v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided July 19, 1961No. 18247_1PublishedCited by 38 opinions

1Opinion of the Court

RIVES, Circuit Judge.

The facts in this tax deficiency case are fully and carefully stated in the opinion of the Tax Court reported at 32 T. C. 390, and may be here summarized with extreme brevity. Prior to 1947 petitioner Hall was engaged, in a small way, in manufacturing equipment he had designed for the cementing of oil wells. In March of 1947 the Gulf Oil Company, convinced of the merit of petitioner’s products, placed an order with him for *84over $500,000 worth of equipment to be delivered in Venezuela. At that time petitioner was doing business as a sole proprietorship — Weatherford…

2Cases cited3 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Dillard-Waltermire, Inc. v. Ellis Campbell, Jr., District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
  3. Commissioner of Internal Revenue v. H. Halpine Smith and George K. Yetter (Mrs. Addie Small Smith, as of the Estate of H. Halpine Smith, Substituted for H. Halpine Smith, Deceased), Berlin Griffin v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1960

3Cited by38 opinions

  1. Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
  2. South Texas Rice Warehouse Co. v. CommissionerUnited States Tax Court · 1965
  3. Ballentine Motor Co., Inc., Ballentine's, and Ballentine Motors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
  4. Brittingham v. CommissionerUnited States Tax Court · 1976
  5. Spicer Theatre, Inc. v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Copley Theatre, Inc.Court of Appeals for the Sixth Circuit · 1965

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