Fuller A. Kimbrell and Reba Kimbrell v. Commissioner of Internal Revenue

RIVES, Circuit Judge:

Taxpayers, Fuller Kimbrell and his wife, Reba Kimbrell, appeal from a decision of the Tax Court holding them liable for deficiencies in income tax for the years 1955 and 1956. We are asked to determine whether the Tax Court erred in finding that certain commission income received during these years by two corporations, allegedly controlled by Fuller Kimbrell, was in fact earned by and taxable to the taxpayers. 1 The Commission er, alleging that the two corporations were not engaged in any business activity but received income for services performed solely by Kimbrell…