Gerd Topsnik v. Commissioner

143 T.C. No. 12

UNITED STATES TAX COURT GERD TOPSNIK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22577-11. Filed September 23, 2014. In 2004, P, a German citizen, made an installment sale of his stock in a U.S. corporation, and he received payments in 2004-09 (years in issue) pursuant to a promissory note executed in connection with the sale. The 2004 payments consisted of a large downpayment and four smaller, equal monthly payments, which continued throughout 2005-09. He filed U.S. individual income tax returns for 2004 and 2005 on which he erroneously reported…