GOODWIN, Judge:
Two decisions of the Tax Court are combined for review. Taxpayers Harlan and Imogene Baxter seek to reverse a decision in favor of the Commissioner, and Taxpayers Lovell and Eva Proby seek to sustain a decision in their favor against the Commissioner. The Commissioner seeks review of the Proby decision only by way of a protective petition, i. e., asking reversal of Proby only if the Baxter decision is reversed.
The facts, substantially as found...
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