Estate of Crews v. Commissioner

*305OPINION.

Van Fossan:

The only matter requiring our consideration is whether or not the $3,000 initial payment made under the Mills contract was taxable income received by the decedent, Crews, in the year 1920. All other issues raised by the pleadings were abandoned by the petitioner.

The contract of sale is a tripartite agreement under which Crews and his daughters engaged to convey their independent interests in the farm to Mills for the consideration therein specified. Crews was. the owner of a life estate in the farm and the daughters were the owners of the fee, and in the agreement of sale…