SIBLEY, Circuit Judge.
Additional income taxes for the year 1933 were assessed against and paid by J. J. Perkins and his wife, Lois Perkins. Denied refund, they sued the collector of internal revenue in the District Court, waiving jury trial. There was no conflict in the evidence. During 1931 they acquired along with others a transfer of an oil and gas lease on Texas land made in consideration of a small amount of cash and of $395,000 to be paid out of oil produced...
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