Welder v. United States

MEMORANDUM AND ORDER

BUE, District Judge.

Plaintiffs, P. H. Welder and Katie Welder, are husband and wife and, since 1957, have resided on their Green Lake Ranch in Calhoun County, Texas. They are cash basis taxpayers. Joint federal income tax returns for each of the years 1958 through 1964 were timely filed by the taxpayers, and any tax shown to be due was timely paid each year. In 1965, a government audit of the taxpayers’ joint return for each of the years 1958 through 1964 was made, resulting in a determination by the Commissioner of Internal Revenue that tax deficiencies existed in the…