Court of Appeals for the Fifth Circuit March 13, 1975, 74--2276 (State National Bank of El Paso, Trustee for Lee Moor Children's Home v. United States)

COLEMAN, Circuit Judge.

This is a suit for the refund of $473,-641.70 in federal income taxes ($348,-050.14 in taxes, plus $125,591.56 interest). The State National Bank of El Paso, the suing taxpayer, is Trustee for the Lee Moor Children’s Home. This, undoubtedly, is a charitable trust. The trust owned a 2875 acre irrigated farm in El Paso County, the largest farm in the County.