William A. LANDRETH, Sr., Mary Adele Landreth Smith, Co-Trustees of W.A. Landreth, Jr., Trust, under the Will of Adele H. Landreth, et al., Plaintiffs-Appellants,
v.
UNITED STATES of America, Defendant-Appellee.
United States Court of Appeals, Fifth Circuit.https://leagle.com/images/logo.png
June 18, 1992.
June 18, 1992.
Attorney(s) appearing for the Case
John D. Mixon, J. Lyndell Kirkley, Brown, Herman, Scott, Deal & Miles, Ft. Worth, Tex., for plaintiffs-appellants.
Lillian D. Brigman, Atty., Tax Div., Dept. of Justice, Dallas, Tex., Steven W. Parks, Gary R. Allen, Chief, Appellate Sec., Richard Farber, U.S. Dept. of Justice, Tax Div., Washington, D.C., for defendant-appellee.
Before REAVLEY, JOLLY and HIGGINBOTHAM, Circuit Judges.
United States Court of Appeals, Fifth Circuit.
REAVLEY, Circuit Judge:
The Landreth trust (Landreth)1 received no cash distributions in 1981, 1982, or 1983 on its net profits interest (NPI)2 in certain oil properties operated by Amoco Oil Company (Amoco). Landreth, a cash method taxpayer, argues that because it received no distributions, it had no gross income and thus no net income for purposes of the windfall profit tax. So Landreth claims that it is...
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