Ulysses G. Trivett, Jr. And Violet W. Trivett v. Commissioner of Internal Revenue

ORDER

This is an appeal from a decision of the United States Tax Court upholding a finding of deficiency in Ulysses G. Trivett, Jr.’s income taxes for 1969. Jurisdiction is conferred upon this court by Section 7482 of the Internal Revenue Code of 1954, 26 U.S.C. § 7482. The decision below is found at 36 T.C. Memo 675 (1977).

In 1969 Trivett sold his Dairy Queen franchise to the American Dairy Queen Corporation (ADQ) for $400,000. ADQ paid him $100,000 in cash on June 19, 1969. On June 20,1969, ADQ signed three promissory notes payable to Trivett, each in the amount of $100,000. The first note…