Commissioner of Internal Revenue v. Crichton

HUTCHESON, Circuit Judge.

In 1936, respondent and her three children, owning, in undivided interests, a tract of unimproved country land and an improved city lot, effected an exchange of interests. Her children transferred to respondent their undivided interest in the city lot. Respondent transferred to her children, as of equal value, an undivided SÁ2 interest in the “oil, gas and other minerals, in, on and under, and that may be produced from” the country land. The Yz interest conveyed to respondent had a value of $15,357.77. The interest respondent transferred to her children had a cost…