John L. Locke and Irene F. Locke v. Commissioner of Internal Revenue

VAN PELT, Senior District Judge:

This is an appeal from a Tax Court decision 1 sustaining a finding by the Commissioner of Internal Revenue that John L. and Irene F. Locke owed a tax deficiency of $11,996.05 for the taxable year ending December 31, 1969 and a tax deficiency of $72,796.60 for the taxable year ending December 31, 1970. We affirm.

John L. Locke, now deceased, was the son-in-law of O. D. Fisher who had developed an extensive corporate enterprise of diversified interests. Locke was the chief executive officer of many of the Fisher corporations, and, in general, had a position of…