SETH, Circuit Judge.
This is a review of a decision of the Tax Court which held that the taxpayer was correct in her position that a lump sum payment received by her for an option to acquire her oil and gas leases was not includable in her income for the year of its receipt.
The record shows that the taxpayer acquired three five-year federal oil and gas leases covering some 6400 acres. She then entered into three agreements, each described as an "option,"...
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