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CUNNINGHAM v. COMMISSIONER

Docket Nos. 5118-63, 5119-63.

44 T.C. 103 (1965)

CUNNINGHAM AND DIANE W. CUNNINGHAM, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. WEAVER CUNNINGHAM AND GWENDOLYN B. CUNNINGHAM, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 27, 1965.

Attorney(s) appearing for the Case

Arch B. Gilbert, A. E. Brooks, and Donald L. Wilson, for the petitioners.

Robert A. Roberts, for the respondent.

TRAIN, Judge:

Respondent has determined income tax deficiencies for 1960 of $377.98 against John I. Cunningham and Diane Cunningham and $111,710.26 against Weaver and Gwendolyn Cunningham.

The issue is whether petitioners realized a taxable gain on the disposal of certain installment obligations arising from the sale of corporate stock.

FINDINGS OF FACT

Most of the facts are stipulated and these are incorporated herein by this reference...

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