The question is whether decedent's rights as lessee thereunder are exempted from estate tax by the provision that ‘The value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated, except real property situated outside of the United States‘; in other words, were the leases ‘real property situated outside the United States,‘ within the meaning of these provisions? Cf. James M. B. Hard, 9 T.C. 57. We think they were.