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UNITED PACIFIC CORPORATION v. COMMISSIONER

Docket No. 85954.

39 T.C. 721 (1963)

UNITED PACIFIC CORPORATION AND CONSOLIDATED SUBSIDIARIES, UNITED PACIFIC INSURANCE COMPANY, PACIFIC NORTHWEST COMPANY, UNITED GENERAL COMPANY, FERRIS & HARDGROVE, INC., UNITED NATIONAL CORPORATION, AND CASCADE INSURANCE COMPANY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 29, 1963.

Attorney(s) appearing for the Case

George W. McBroom, Esq., for the petitioners.

Norman H. McNeil, Esq., for the respondent.

OPINION.

MULRONEY, Judge:

The respondent determined a deficiency in petitioners' income tax for the year 1955 in the amount of $38,469.08. The sole issue is whether, in determining whether petitioners received payments in the year of sale of mortgaged real property in excess of 30 percent of the selling price within the meaning of the installment sale provisions, the excess of the mortgage over petitioners...

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