Putoma Corp., Successor by Merger of Pro-Mac Company, Petitioners- Cross-Appellants v. Commissioner of Internal Revenue, Cross-Appellee

SKELTON, Senior Judge.

This is an income tax case that involves an appeal by the Commissioner of Internal Revenue (Commissioner or Government) from a decision of the United States Tax Court, and cross-appeals by Putoma Corporation (Putoma), successor by merger of Pro-Mac Company (Pro-Mac), with J. M. Hunt and wife, Inez Hunt, as appellees in the appeal of the Commissioner.

At all times pertinent to this case, Puto-ma Corporation and Pro-Mac Company were Texas corporations using the accrual basis of accounting.

The Commissioner of Internal Revenue appeals from decisions of the Tax Court in which…