AINSWORTH, Circuit Judge:
The Government appeals from an adverse District Court decision in favor of Taxpayers, C. B. and Ida N. Christie, on their claim for refund of income taxes paid for the calendar year 1964. At issue is the question of ownership of an economic interest in oil in place on property covered by a certain mineral lease in Texas. The District Court held that an assignment of an oil production payment by Taxpayers to Waldo E. Karrenbrock transferred...
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