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SUNRAY OIL CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 3059.

147 F.2d 962 (1945)

SUNRAY OIL CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Tenth Circuit.

Rehearing Denied March 16, 1945.

Attorney(s) appearing for the Case

Edward Howell and John M. Wheeler, both of Tulsa, Okl., for petitioner.

Warren F. Wattles, of Washington, D. C. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and John F. Costelloe, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before PHILLIPS, BRATTON, and MURRAH, Circuit Judges.

PHILLIPS, Circuit Judge.

This is a petition of the Sunray Oil Company1 to review a decision of the Tax Court. It involves income taxes for the years 1936 to 1939, inclusive.

During 1936, the State of Oklahoma granted to the taxpayer thirteen oil and gas leases upon tracts of land owned by the state. The taxpayer paid bonuses or advance royalties therefor aggregating $446,000. In 1937, the taxpayer purchased an undivided one-fourth...

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