LEE, Circuit Judge.
The petition for review involves income taxes for the year 1937 and presents the following questions:
1. Was the petitioner, who, as assignee of a producing oil and gas lease, was required to develop and operate the lease and to account to the lessee-assignor for one-fourth of the net profits from said lease, entitled to deduct such payments in computing its taxable net income, either as business expenses or as rentals or royalties?
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