WALKER, Circuit Judge.
The petitioner challenges the decision of the Board of Tax Appeals that one-half of the amounts of bonus money paid in 1929 to the respondent, the taxpayer, by the lessee under two oil and gas leases made by the respondent, covering land the surface right to which was owned by the respondent, the right to minerals in that land having been reserved by the state of Texas when it granted the surface rights therein, was not taxable as income of...
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