GRONER, J.
Petitioner is a Delaware corporation operating in Oklahoma. In its tax return for the year 1930 it deducted approximately $145,000 as a loss sustained in that year. The Commissioner disallowed the deduction, and the Board sustained his ruling.
Petitioner began to do business January, 1916. At that time it acquired from four brothers $100,000 in cash and approximately seven millions of dollars worth of oil leases, mining rights, and royalty interests...
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