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LUDLOW v. COMMISSIONER

Docket No. 77570.

36 T.C. 102 (1961)

LEWIS M. LUDLOW AND HARRIET M. LUDLOW, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 18, 1961.

Attorney(s) appearing for the Case

Endicott Peabody, Esq., and Kingsbury Browne, Jr., Esq., for the petitioners.

Douglas D. Robertson, Esq., for the respondent.

MULRONEY, Judge:

Respondent determined a deficiency in the petitioners' income tax for 1955 in the amount of $23,154.16. The only issue is whether the petitioners are entitled to report the income from the sale of certain shares of stock in 1955 on the installment basis within the meaning of section 453 of the Internal Revenue Code of 1954.

FINDINGS OF FACT.

Some of the facts have been stipulated and they are hereby incorporated by this reference...

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