Michael v. Commissioner

OPINION.

Phillips :1

These proceedings involve the 1922 individual income tax liability of five individuals, three of whom are residents of Buffalo, N. Y., and two residents of New York City. The deficiencies in controversy are as follows:

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The five cases involve a number of issues which are common to all of them and by order of the Board dated December 7, 1929, they were consolidated for purposes of hearing.

One of the common issues is raised by the petitioners’ claim that the deficiency in each of these cases is a second determination of defi*640ciency in respect of the same taxable…