Chesson v. Commissioner of Internal Revenue

BRYAN, Circuit Judge.

Petitioner, being the owner of 51 acres of land in Texas, granted three separate oil and gas leases which together covered the whole tract; the lessees obligating themselves to deliver to his credit in pipe lines either a sixth or an eighth of the oil produced. He was a single man when he executed the first two leases, but was married shortly before the date of the third lease, in which he was joined by his wife. The Board of Tax Appeals held that the money he received from the sale of oil as provided in each of the leases was his separate income. 22 B. T. A. 818.

The land…