SIBLEY, Circuit Judge.
The taxpayer, Badger Oil Company, owning a producing oil lease on Texas land, and having afterwards acquired title to the fee in the land except about one-third of the one-eighth royalty, in the tax year 1935 transferred the lease to International Petroleum Corporation for $200,000 in cash and $165,000 in secured notes which were paid off during the year. Of the $365,000 received, $60,000 was for personal property, $305,000 for the oil property...
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