OPINION.
TIETJENS, Judge:
The Commissioner determined deficiencies in income tax of $70,152.85 and $47,449.05 for the years 1953 and 1954, respectively.
The only issue for decision is whether petitioner properly may report amounts received as advance royalties or bonuses in the form of cash and negotiable notes on an oil and gas lease for a primary period of 10 years executed July 17, 1953, on the installment basis or must report the total...
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