Roberts v. Commissioner
United States Tax Court
Held, petitioner properly used the installment method in reporting income from the sale of stock to a trust of which he was grantor.
1Opinion of the Court
Sterrett, Judge:
Respondent, on January 11, 1977, issued a statutory notice in which he determined the following deficiencies in petitioners’ Federal income tax:
Taxable year Amount
1971 .... $117,006.19
1972 .... 216,843.00
1973 .... 10,319.03
The sole issue for our determination is whether petitioners properly elected to report the gain resulting from the sale of certain stock on the installment basis under section 453, I.R.C. 1954.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts, together with the exhibits attached thereto, are incorporated herein…
2Cases cited8 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Rushing v. CommissionerUnited States Tax Court · 1969
- W. B. Rushing v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
- Pityo v. CommissionerUnited States Tax Court · 1978
- Wrenn v. CommissionerUnited States Tax Court · 1976
3 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Gordon v. CommissionerUnited States Tax Court · 1985
- Goodman v. CommissionerUnited States Tax Court · 1980
- Weaver v. CommissionerUnited States Tax Court · 1978
- Bowen v. CommissionerUnited States Tax Court · 1982
- Paul G. Lustgarten and Jacqueline Lustgarten v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981
14 more not listed; retrieve them via the Exa API.