D. M. Haggard and Nila Haggard v. Commissioner of Internal Revenue

This was a proceeding in the Tax Court, wherein a decision sustaining a deficiency against the Haggards, as taxpayers, was entered. Review of the decision by this Court is asked.

The Haggards are operators of a ranch in Arizona. On February 9, 1948, two documents were entered into simultaneously between one Butler and the Hag-gards. The effect of these instruments was to lease 160 acres of land to the Hag-gards for the rest of 1948 for $10,000.00, for 1949 for $12,000.00, to grant an option for $2,000.00 cash to purchase the tract after January 1, 1950, and before January 10, 1950, for…