Raymond and Lillie H. Robinson v. Commissioner of Internal Revenue

Petitioner and his wife seek to overturn a decision of the Tax Court which upheld a deficiency assessment against them for federal income tax liability for 1964.

Petitioner attempted to gain the beneficial income tax treatment of 26 U.S..C. A. § 453 by selling his insurance agency on an installment basis. Section 453(b) provides for deferred reporting of the gain from the installment sale of assets if in the year of the sale the payments received do not exceed 30% of the selling price. Before selling the business, petitioner spoke to the Internal Revenue Service and to his personal tax advisor…