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COMMISSIONER OF INTERNAL REVENUE v. WILLIAMS

No. 7826.

82 F.2d 328 (1936)

COMMISSIONER OF INTERNAL REVENUE v. WILLIAMS.

Circuit Court of Appeals, Fifth Circuit.

March 11, 1936.

Attorney(s) appearing for the Case

Helen R. Carloss, F. E. Youngman, and Sewall Key, Sp. Assts. to Atty. Gen., Frank J. Wideman, Asst. Atty. Gen., and Robert H. Jackson, Asst. Gen. Counsel, Bureau of Internal Revenue and W. R. Lansford, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for petitioner.

Charles H. Garnett, of Oklahoma City, Okl., for respondent.

Before FOSTER, HUTCHESON, and WALKER, Circuit Judges.

WALKER, Circuit Judge.

In 1927 the respondent and certain other individuals, owners of the oil and gas rights in certain Texas lands, sold and conveyed their interest in and to said oil and gas rights to two individuals, the consideration being the payment by the vendees to the vendors of $110,000 in cash, and the agreement of the vendees, after they had recovered $160,000 from the gross sales of seven-eighths of the oil produced, to pay the vendors one-half of the...

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