Court of Appeals for the Ninth Circuit November 23, 1979, 77-2026, 78-2036 (Lee E. Coombs and Judy B. Coombs v. Commissioner of Internal Revenue, James C. Cox v. United States)

WALLACE, Circuit Judge:

Two groups of taxpayers appeal from two sets of unfavorable judgments, one entered by the Tax Court and one entered by the district court. The appellants in No. 77-2026 are taxpayers whose fifty-two cases were consolidated for trial in the Tax Court. The Tax Court’s opinion,

Coombs v. Commissioner,

is reported at 67 T.C. 426 (1976). The appellants in No.