Simms Oil Co. v. Commissioner

CHASE, Circuit Judge.

Three unrelated questions are presented for review. They will be considered separately and the essential facts as to each stated in connection with the point discussed.

E. F. Simms, a man interested in the oil business in Texas, in 1919' bought a considerable number of leases on what it was hoped would prove to be profitable oil-bearing land scattered through twenty counties in Texas. All hut one were adjoining counties. The general location of the land was favorable and the time auspicious for a development not only of oil production but of a stock holding and stock…