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DAVIS v. C.I.R.

Nos. 81-1126, 81-1127 and 81-1187.

746 F.2d 357 (1984)

Joe C. DAVIS, Estate of Rascoe B. Davis, Third National Bank, Executor and Delta C. Davis, Petitioners-Appellants, Cross Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee (81-1127), Cross Appellant (81-1187). Joe C. DAVIS, Petitioner-Appellant, Cross Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee (81-1126), Cross Appellant (81-1187).

United States Court of Appeals, Sixth Circuit.

Decided October 24, 1984.

Attorney(s) appearing for the Case

William Waller, Lawrence Dortch, Charles A. Trost (argued), Nashville, Tenn., for petitioners-appellants, cross appellees.

N. Jerold Cohen, Chief Counsel, I.R.S., M. Carr Ferguson, Asst. Atty. Gen., John F. Murray, Michael L. Paup, Richard Farber, James A. Riedy, Gilbert S. Rothenberg (argued), Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee, cross appellant.

Before ENGEL and KEITH, Circuit Judges, and WEICK, Senior Circuit Judge.

WEICK, Senior Circuit Judge.

These consolidated appeals by the taxpayers and the Commissioner of Internal Revenue are from decisions of the United States Tax Court, rendered by a sharply divided court.

There are two issues involved. The principal issue is whether section 631(c) of the Internal Revenue Code (Code), 26 U.S.C. § 631(c), which permits a sublessor of coal mining rights to treat the royalties he receives from a sublessee of those rights as...

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