Jones v. Commissioner

GEWIN, Circuit Judge.

These consolidated cases1 relate to the income tax liability of A. Raymond Jones (and his wife, Mary Lou) 2 for the years 1951 and 1953 3; and the liability of Drilling Accessory & Manufacturing Company, Inc.,4 (referred to as Drilling) resulting from a deficiency asserted by the Commissioner of Internal Revenue for the taxable year May 1, 1953 to January 31, 1954. Jones (sometimes referred to as taxpayers) filed petition for review in Case No. 75149; and the Commissioner seeks review in Case No. 75196 only to protect the revenue in the event the individual taxpayers,…