Anaheim Union Water Company v. Commissioner of Internal Revenue, Santa Ana River Development Co. v. Commissioner of Internal Revenue

The petition for review in these cases involves income taxes of petitioners Anaheim Union Water Company (hereinafter “Anaheim”) and Santa Ana River Development Company (hereinafter “SARD”) for the years 1952, 1953, and 1954.

On December 12, 1957, the Commissioner of Internal Revenue (hereinafter “Respondent”) mailed to Anaheim a notice of deficiency, advising that for the years 1952, 1953, and 1954, he had determined deficiencies in the respective amounts of $39,219.33, $35,009.46, and $35,366.29. On the same date, Respondent notified SARD by mail that for the years 1952, 1953, and 1954 he had determined deficiencies in the respective amounts of $2,274.34, $3,114.28, and $5,-306.44. On March 6, 1958, Anaheim and SARD filed separate petitions with the Tax Court of the United States, pursuant to Section 6213, Internal Revenue Code, 1954, seeking redeterminations of the deficiencies. Both cases were consolidated for trial in the Tax Court and were decided in a single opinion of the Court wherein the deficiencies determined by Respondent as to both Anaheim and SARD were sustained. 35 T.C. 1072 . Anaheim and SARD then filed m this court a joint petition for review of the decision of…