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YATES v. C.I.R.

No. 89-9013.

924 F.2d 967 (1991)

Richard M. and Brenda R. YATES, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

January 23, 1991.

Attorney(s) appearing for the Case

Arnold C. Wegher, Denver, Colo. (A.J. Losee and James E. Haas of Losee, Carson, Haas & Carroll, P.A., Artesia, N.M., with him on the brief), for petitioners-appellants.

Teresa T. Milton (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen and David English Carmack, with her on the brief), Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before SEYMOUR, TACHA and BRORBY, Circuit Judges.

BRORBY, Circuit Judge.

Taxpayers appeal an adverse tax court decision.

Taxpayers acquired three separate oil and gas leases of federal minerals through the federal oil and gas lottery. Their cost for each lease was a $10 filing fee and $1 per acre annual delay rental. These three leases covered acreage in North Dakota and in two Wyoming counties, Campbell and Converse. The North Dakota lease was acquired in 1975 and...

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