M. O. Rife and Maidee W. Rife v. Commissioner of Internal Revenue

MOORE, Circuit Judge:

This is a petition to review a decision of the Tax Court, 41 T.C. 732 (1964), affirming the assessment of income tax deficiencies for the years 1954, 1955 and 1956 against petitioners M. O. Rife and Maidee W. Rife, husand and wife (hereinafter referred to collectively as petitioner), which resulted in large part from the disallowance of deductions claimed for drilling expenses in 1955, 1956 and 1957 and their deferral to succeeding calendar years. 1

During the years involved, petitioner owned and operated Rife Production Company (hereinafter referred to as Production), a…