PHILLIPS, Circuit Judge.
This is a proceeding to review a decision of the Board of Tax Appeals. The petitioner was the owner of an oil and gas lease acquired prior to March 1, 1913. On that date, its recoverable oil reserves were 278,000 barrels and the value thereof was $156,645. On January 15, 1916, petitioner acquired an extension of its lease for a consideration of $30,000, which increased its recoverable oil reserves by 300,000 barrels.
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