Nos. 399-70, 400-70. May 18, 1971. David H. Loeffler, Bristow, Okla., for appellants. James H. Bozarth, Atty., Tax Division, Dept. of Justice, Washington, D.C. (Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks and Loring W. Post, Attys., Tax Division, Dept. of Justice, with him on the briefs), for appellee. Before SETH, ADAMS, and McWILLIAMS, Circuit Judges. Of the Third Circuit, sitting by designation. SETH, Circuit Judge. These appeals involve personal federal income taxes for the years 1959