Legal Opinion

James M. Tunnell, Jr., and Mildred S. Tunnell v. The United States of America, Robert W. Tunnell and Eolyne K. Tunnell v. The United States

Court of Appeals for the Third Circuit

Decided April 23, 1975No. 74-1675, 74-1678PublishedCited by 10 opinions

1Opinion of the Court

ROSENN, Circuit Judge.

Taxpayers, Eolyne K. and Robert W. Tunnell, and Mildred S. Tunnell and James M. Tunnell, Jr., formed two partnerships to develop and operate two mobile home parks known as “Pot Nets” and “Indian Landing” in Sussex County, Delaware. 1 Third parties lease lots on a long term basis in both parks for the purpose of placing thereon mobile homes for use as summer and weekend dwellings.

Both mobile home parks are situated on land which, in its original state, was part marsh, part cultivated, and part forested. Low-lying marshes separated the wooded and cultivated areas from the…

2Cases cited4 opinions

  1. Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
  2. Crosby v. United StatesCourt of Appeals for the Fifth Circuit · 1974
  3. Hoffman Motors Corp. v. United StatesCourt of Appeals for the Second Circuit · 1973
  4. Tunnell v. United StatesDistrict Court, D. Delaware · 1973

3Cited by10 opinions

  1. Zimmerman v. CommissionerUnited States Tax Court · 1976
  2. Gary Everson and Mary Everson v. United StatesCourt of Appeals for the Ninth Circuit · 1997
  3. The Fed-Mart Corporation, a California Corporation v. The United States of AmericaCourt of Appeals for the Ninth Circuit · 1978
  4. Shell Petroleum, Inc. v. United StatesDistrict Court, D. Delaware · 1997
  5. Merhow Industries, Inc. v. United StatesDistrict Court, N.D. Indiana · 1981

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