Carl A. Prater and Della Jane C. Prater, Husband and Wife v. Commissioner of Internal Revenue

HUTCHESON, Circuit Judge.

This petition, involving income taxes for the years 1950, 1951, and 1952, brings up for review a decision and opinion of the Tax Court, 30 T.C. 1262. While nominally presenting two questions, in reality it presents a single question for review. This is whether petitioner Prater and his wife, hereafter referred to as Prater, owners of a one-fourth carried working interest in certain oil and gas properties (under an agreement with the carrying parties that, while petitioners were not to be personally liable for expenses and losses of the initial development, their…