Sunray Oil Co. v. Commissioner of Internal Revenue

PHILLIPS, Circuit Judge.

This is a petition of the Sunray Oil Company 1 to- review a decision of the Tax Court. It involves income taxes for the years 1936 to 1939, inclusive.

During 1936, the State of Oklahoma granted to the taxpayer thirteen oil and gas leases upon tracts of land owned by the state. The taxpayer paid bonuses or advance royalties therefor aggregating $446,-000. In 1937, the taxpayer purchased an undivided one-iourth interest in another oil and gas lease upon a tract of state-owned land, paying therefor $77,868.82. In 1937, the taxpayer acquired a three-fourths interest in an…