John J. Kalbac and Dorothy Kalbac v. Commissioner of Internal Revenue, John G. Kiske and Clara Kiske v. Commissioner of Internal Revenue

SANBORN, Circuit Judge.

The facts which gave rise to these petitions for review of decisions of the Tax Court are not in dispute. Francis J. Mulligan, President of the James Mulligan Printing Company, of St. Louis, Missouri, and owner of 198 of the 200 shares of its capital stock, died June 10, 1952. John J. Kalbac and John G. Kiske (who alone will be referred to as petitioners, their wives being nominal parties) had been for many years — Kalbac for about 30, and Kiske for 40 — employees of the Company as well as business associates and close friends of Francis J. Mulligan. In his later years…