Herberger

Petitioners, George and Mabel Her-berger, seek review and reversal of two decisions of the Tax Court determining income tax liability for 1942, 1943 and 1944, one determining George’s liability and one determining Mabel’s liability.

During the taxable years, petitioners were husband and wife, resided in California and were engaged in the business of processing and selling pickles. 2Most of their income was derived from that business. All their income was community, income — income L. which their interests were equal.

Petitioners bought for cash, not on credit, the cucumbers and other materials and supplies used in their business. They usually sold for cash, not on credit, the pickles they processed. Occasionally, however, pickles sold in one year were paid for in the following year. Thus petitioners received '$171.40 in 1943 for pickles sold in 1942 and received $946.86 in 1944 for pickles sold in 1943. The method of accounting regularly employed in keeping petitioners’ books was the cash receipts and disbursements method. Petitioners’ income tax returns were made on a cash basis.

Petitioners sold 1626 barrels of pickles to Henry Harmel and received therefor $29,268 in three…