Jay H. Floyd and Julia M. Floyd v. Commissioner of Internal Revenue
This text of 309 F.2d 95 (Jay H. Floyd and Julia M. Floyd v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinions
This case presents a single question, whether the proceeds from the assignment by petitioners of certain in-oil payment rights constitute capital gain or ordinary income. All the facts are stipulated and are found in accordance with the stipulation.
The Tax Court held that the case cannot be distinguished from that of Commissioner v. P. G. Lake, 356 U.S. 260, 78 S.Ct. 691, 2 L.Ed.2d 743, and that the proceeds are taxable as ordinary income.
We agree with the Tax Court that this is so in this case and affirm its judgment.
Affirmed.
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Cite This Page — Counsel Stack
309 F.2d 95, 17 Oil & Gas Rep. 247, 10 A.F.T.R.2d (RIA) 5630, 1962 U.S. App. LEXIS 4044, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jay-h-floyd-and-julia-m-floyd-v-commissioner-of-internal-revenue-ca5-1962.