Legal Opinion

J. L. Enochs, District Director of Internal Revenue v. Williams Packing & Navigation Co., Inc.

Court of Appeals for the Fifth Circuit

Decided June 14, 1961No. 18272PublishedCited by 15 opinions

1Opinion of the Court

CAMERON, Circuit Judge.

This appeal presents two questions; whether fishermen carrying on their occupation of catching shrimp and oysters aboard trawlers, owned or leased by Williams Packing & Navigation Company, Inc., taxpayer-appellee, were its employees during the taxable periods involved within the meaning of §§ 1426 and 1607 of the Internal Revenue Code of 1939 and §§ 3121 and 3306 of the Internal Revenue Code of 1954; and whether taxpayer has shown the existence of such extraordinary and unusual circumstances as to wax-rant the granting of an injunction notwithstanding the prohibitions…

2Cases cited15 opinions

  1. Taylor v. SecorSupreme Court of the United States · 1876
  2. Miller v. Standard Nut Margarine Co. of Fla.Supreme Court of the United States · 1932
  3. Hill v. WallaceSupreme Court of the United States · 1922
  4. Allen v. Regents of the University SystemSupreme Court of the United States · 1938
  5. Dodge v. BradySupreme Court of the United States · 1916

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3Cited by15 opinions

  1. Enochs v. Williams Packing & Navigation Co.Supreme Court of the United States · 1962
  2. United States v. Joe Grasso & Son, Inc.Court of Appeals for the Fifth Circuit · 1967
  3. Cape Shore Fish Co., Inc. v. The United StatesUnited States Court of Claims · 1964
  4. United States v. Crawford Packing CompanyCourt of Appeals for the Fifth Circuit · 1964
  5. Joseph Poretto Joseph Marcello, Jr. Natural Persons D/B/A Nola Printing Company v. Chester A. Usry, Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961

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