Mray A. Maher and Rose M. Maher v. Commissioner of Internal Revenue, Ray A. Maher, Transferee v. Commissioner of Internal Revenue

MATTHES, Chief Judge.

These appeals are from two decisions of the Tax Court, one sustaining a deficiency income tax assessment of $184,-073.30 against Ray A. Maher and his wife, Rose, 1 the other sustaining taxpayer’s liability as transferee. Taxpayer has filed two appeals, one on behalf of himself and his wife, and one solely on behalf of himself as transferee. The Commissioner of Internal Revenue, while seeking affirmance of the Tax Court’s decisions, has filed protective appeals in both eases. All appeals have been consolidated.

The facts, which are not in dispute, are fully delineated in…