Ballentine Motor Co., Inc., Ballentine's, and Ballentine Motors, Inc. v. Commissioner of Internal Revenue

BOREMAN, Circuit Judge.

This is an appeal from a decision of the Tax Court 1 upholding the assessment of income tax deficiencies by the Commissioner of Internal Revenue. Separate petitions, filed by taxpayers, were consolidated for hearing, briefing and disposition before the Tax Court. That Court’s findings of fact, which appear to be fully supported by the evidence, are not disputed. Challenged here by taxpayers are the inferences and conclusions drawn by the Tax Court from the facts.

During the period pertinent to these proceedings, C. M. Ballentine was the president and controlling…