RYAN v. COMMISSIONER

Docket No. 94778.

42 T.C. 386 (1964)

HULOND R. AND MARY R. RYAN, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 14, 1964.


Attorney(s) appearing for the Case

J. Gilmer Blackburn, for the petitioners.

Ford P. Mitchell, for the respondent.


DRENNEN, Judge:

Respondent determined deficiencies in petitioners' income tax for the years 1956 and 1957 in the amounts of $17,584.80 and $34,262.88, respectively. By stipulation petitioners conceded all adjustments in the notice of deficiency except adjustments with respect to dealer reserve income.

The only issues remaining for decision are (1) whether petitioners' change in method of reporting dealer reserve income for their taxable year 1957 constituted...

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