Oden v. Commissioner
United States Tax Court
In 1963, petitioners reported the proceeds from the sale of certain property under the installment sale provisions of sec. 453, I.R.C. 1954. Respondent determined that petitioners were not entitled to use that method on the ground that they received more than 30 percent of the selling price in the year of sale. Held, on the record, respondent's determination sustained.
1Opinion of the Court
IrwiN, Judge:
The Commissioner determined deficiencies in income tax as follows:
Docket No. Year Amount
5546-67_ 1963 $16, 843. 16
293-68_ 1963 17, 360. 9
294-68_ 1963 9, 755. 9
The only issue for decision is whether petitioners were entitled to use the' installment method of reporting income as provided in section 453 of the Internal Revenue Code of 1954.2
FINDINGS OF FACT
Some of the facts have been stipulated by the parties. The stipulation and the exhibits attached thereto are incorporated herein by this reference.
Petitioners are J. Earl Oden (hereinafter Earl) and his wife Edith Oden, John S.…
2Cases cited10 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- H. O. Williams and Mrs. Ada L. Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1955
5 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Stiles v. CommissionerUnited States Tax Court · 1978
- John E. Reed v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1983
- Watson v. CommissionerUnited States Tax Court · 1978
- Ulysses G. Trivett, Jr. And Violet W. Trivett v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1979
- John H. Rickey and Lorraine C. Rickey v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974
23 more not listed; retrieve them via the Exa API.