Plantation Patterns, Incorporated v. Commissioner of Internal Revenue, John S. Jemison, Jr. And Marie S. Jemison v. Commissioner of Internal Revenue

SIMPSON, Circuit Judge:

This is an appeal from a determination by the Tax Court of tax deficiencies against the corporate taxpayer, Plantation Patterns, Incorporated (New Plantation hereinafter, to distinguish it from an earlier corporation with the same name) for the fiscal years ending September 30, 1963-65, for the respective amounts of $2,947.12, $51,719.69, and $23,732.28, and against the individual taxpayers, John S. Jemison, Jr. (Mr. Jemison) and his wife, Marie S. Jemison (Mrs. Jemison) of $28,403.91 for their taxable year 1963. 1 The cases were consolidated for trial in the Tax Court…