Legal Opinion

Crowell Land and Mineral Corporation v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided April 12, 1957No. 16016PublishedCited by 61 opinions

1Opinion of the Court

HUTCHESON, Chief Judge.

Crowell Land and Mineral Corporation petitions for a review of a decision of the Tax Court, 1 three judges dissenting, sustaining the Commissioner in assessing against it for the year 1949 an income tax deficiency in the amount of $1,839.12. The maj'ority concluded that Crowell’s income in that year of $14,-147.04, derived from sand and gravel removed from its lands pursuant to a written contract of sale by it as “vendor” with full warranty of title to GiffordHill and Company, Inc., as “vendee”, was taxable as ordinary income rather than as gain derived from the sale of…

2Cases cited9 opinions

  1. Anderson v. HelveringSupreme Court of the United States · 1940
  2. Thomas v. PerkinsSupreme Court of the United States · 1937
  3. Crowell Land & Mineral Corp. v. CommissionerUnited States Tax Court · 1955
  4. United States v. RobinsonCourt of Appeals for the Fifth Circuit · 1942
  5. Camp Mfg. Co. v. CommissionerUnited States Tax Court · 1944

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3Cited by61 opinions

  1. Nathaniel C. Wood and Gertrude L. Wood v. United StatesCourt of Appeals for the Fifth Circuit · 1967
  2. William Louis Albritton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
  3. Arthur S. Barker and Alberta C. Barker v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
  4. Dann v. CommissionerUnited States Tax Court · 1958
  5. Earl Vest and Fay Vest, Petitioners-Appellees-Cross v. Commissioner of Internal Revenue, Respondent-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973

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

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