Marion C'de Baca v. Commissioner of Internal Revenue

TUTTLE, Chief Judge.

This petition to review a decision of the Tax Court raises the question whether a taxpayer loses the right to report a sale of real estate as an installment sale if he negligently fails to file a return for the tax year in question.

The relevant facts are all stipulated'.. Those essential to our consideration of the case are: Petitioner was a single-woman residing in Amarillo, Texas, during 1953. During that year she received $118,400.00 for the sale of her farm inHale County, Texas, representing a gain of $90,911.00, which, of course, was taxable income to her. She failed…