C. B. v. Comm'r, 410 F.2d 759 (5th Cir. 1969). · Go Syfert
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C. B. v. Comm'r, 410 F.2d 759 (5th Cir. 1969). Cases Citing This Book View Copy Cite
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C. B., Jr. and Martha Jean CHRISTIE, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee
26663.
Court of Appeals for the Fifth Circuit.
Apr 28, 1969.
Published opinion
410 F.2d 759
1969 U.S. App. LEXIS 12632
Harold D. Rogers, Wichita Falls, Tex., for petitioners-appellants., Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Harry Marselli, Attys., Tax Div., U. S. Dept, of Justice, Washington, D. C., Lester R. Uretz, Chief Counsel, I. R. S., Washington, D. C., Grant W. Wiprud, Dept, of Justice, Washington, D. C., David English Car-mack, Attys., for respondent-appellee.
Bell, Thornberry, Choate.
Cited by 8 opinions  |  Published
PER CURIAM:

The Tax Court concluded that the substance of the transaction here involved was that taxpayers owned the working interest in the oil lease and that the effort to carve out a production payment from the working interest was without legal efficacy. While a close case is presented on the facts, we are convinced after careful study that there is a sufficient evidentiary basis for the decision" of the Tax Court and that there is no error in law. The clearly erroneous rule applies in our review of decisions of the Tax Court. C. I. R. v. Du-[*760] berstein, 1960, 363 U.S. 278, 80 S.Ct. 1190, 4 L.Ed.2d 1218; Estate of Broadhead v. C. I. R., 5 Cir., 1968, 391 F.2d 841. There having been no separate economic interests, it follows that G. C. M. 24994, 1944, Cum.Bull. 250, had no applicability.

The decision of the Tax Court is affirmed.