ATKINS, Judge:
The respondent determined a deficiency in income tax for the calendar year 1955 in the amount of $362,712.99. The issue for decision is whether, as contended by the petitioner Howard Glenn, an amount of $900,000 received by him in 1955 constituted selling price of his 98 percent working interest in the oil and gas underlying certain land owned by him and is therefore taxable to him as long-term capital gain, or whether, as contended by the respondent...
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