COHEN, Judge:
Respondent determined deficiencies of $131,475 and $52,497 in petitioners' Federal income tax for 1981 and 1982, respectively. The sole issue for decision is whether cash payments received by petitioners in 1981 and 1982 for the transfer of interests in oil and gas leases should be treated as ordinary income subject to depletion or as long-term capital gains.
Unless otherwise indicated, all Rule references are to the Tax Court Rules of...
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