Mingo v. Commissioner

JAMES E. GRAVES, JR., Circuit Judge:

In 2002, Petitioners-Appellants Lori M. Mingo and John M. Mingo, married taxpayers, reported the sale of a partnership interest, including the portion of the proceeds attributable to the partnership’s unrealized receivables (“unrealized receivables”), through the installment method of accounting. In an action brought to determine their federal income tax liability, the tax court held that the Mingos were not entitled to utilize the installment method to report the unrealized receivables. The tax court further held that the Commissioner of Internal Revenue…