United States v. Frazell

335 F.2d 487 (1964)

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United States v. Frazell

United States Court of Appeals for the Fifth Circuit
335 F.2d 487 (1964)

  • Written by Heather Whittemore, JD

Facts

William Frazell (plaintiff) entered into a contract with N. H. Wheless Oil Company (Wheless) and W. C. Wolff. Frazell determined whether land contained gas and oil for future production and acquired the land for Wheless and Wolff. To do this, Frazell consulted valuable oil maps and geological data. The land was then transferred to W.W.F. Corporation (the partnership). In exchange, Frazell was paid a monthly salary and interests in the partnership. Frazell was given 6,500 shares of the partnership, valued at $91,000. Frazell did not include the value of the shares on his income-tax return. The Commissioner of Internal Revenue (the Commissioner) (defendant) assessed a deficiency against Frazell, arguing that the value of the shares should have been included in his income. Frazell appealed, and the district court reversed the Commissioner, finding instead that the value of the shares was not taxable income. The Commissioner appealed.

Rule of Law

Issue

Holding and Reasoning (Tuttle, C.J.)

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