Commissioner v. Lewis

BRATTON, Circuit Judge.

This is a petition to review an order of the Board of Tax Appeals.- The partnership of Cromwell and Lewis purchased non-producing oil and gas leases covering lands in Kansas for a consideration of $120. In 1937, the partners and Atlantic Refining Company entered into a contract which provided that the former sold, conveyed, assigned, transferred, and set over to the latter the leases and the equipment on the premises for $150,000 in cash, and $125,000 payable out of oil produced from the premises ; that the vendors reserved unto themselves one-fourth of seven-eighths of…