William P. Burrell and Billie Joe Burrell v. Commissioner of Internal Revenue, Engine Rebuilders, Inc. v. Commissioner of Internal Revenue

ORIE L. PHILLIPS, Circuit Judge.

These cases are here on petitions to review decisions of the Tax Court. In No. 9822, the Tax Court sustained a deficiency determined by the Commissioner of Internal Revenue in income taxes of the Burrells 1 for the year 1962. In No. 9823, the Tax Court sustained deficiencies determined by the Commissioner of Internal Revenue in income taxes of Engine Rebuilders, Inc., 2 for its fiscal years ended October 31, 1963 and 1964, respectively. For reasons which will hereinafter appear, the cases were consolidated for hearing in the Tax Court and in this court.

Both…