Ralph Dessauer and Rebecca Dessauer v. Commissioner of Internal Revenue

HENLEY, Chief District Judge.

This is a petition to review a determination of the Tax Court fixing the federal income tax liabilities of petitioner, Ralph Dessauer of Springfield, Missouri, for calendar years 1964 and 1965. Des-sauer v. Commissioner of Internal Revenue, 54 T.C. 327 (1970). Petitioner’s wife who was a party to the returns filed by petitioner is a nominal party to this action, but for practical purposes her presence in the ease can be ignored. Most of the facts in the case have been stipulated.

During 1964 and 1965 taxpayer owned 70 percent of the stock in Huddleston Brothers…