George K. Ford and Helen L. Ford v. Commissioner of Internal Revenue

BONE, Circuit Judge.

This case was appealed to this Court by the taxpayers, after a determination in the Tax Court in favor of the Commissioner.1 Because the deficiencies asserted by the Commissioner against Helen L. Ford and George K. Ford were identical, and the issue presented in each petition was identical, the cases were consolidated before the Tax Court.

Only the computations for the years 1943 and 1944 (prepared by the Commissioner) were in issue before the Tax Court and these only because they were challenged by the taxpayers. In its reported opinion, the Tax Court stated that “because…