Andrew M. Spheeris and Ismene Spheeris v. Commissioner of Internal Revenue

ENOCH, Senior Circuit Judge.

The petitioners-appellants, Andrew M. Spheeris and Ismene A. Spheeris, his wife, who is a party only because she and her husband filed joint federal income tax returns for the years here involved, appeal from a decision of the Tax Court 54 T.C. 1353, adverse to the petitioners-appellants. As used below “petitioner” refers to Andrew M. Spheeris.

This cause arose out of the following described situation. In 1945 the Spheer-is Realty Company was formed to own and manage rental property including a parcel, called the Wells Street property in downtown Milwaukee,…