TUTTLE, Circuit Judge.
This is a petition for review of a decision of the Tax Court holding that an absolute transfer for value of $854,993.25 in "oil payments" to a transferee until he received $120,000.00 from such payments, with automatic reconveyance to the transferor thereafter, was a sale or exchange of capital assets, and did not, as the Commissioner of Internal Revenue asserted, result in the receipt of ordinary income.
The facts regarding the transfer...
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