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BRANHAM v. COMMISSIONER

Docket No. 2956-67.

51 T.C. 175 (1968)

JOF D. BRANHAM AND BLANCHE M. BRANHAM, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 28, 1968.

Attorney(s) appearing for the Case

Donald P. Moyers and William A. Goffe, for the petitioners.

Robert S. Leigh, for the respondent.

FAY, Judge:

Respondent determined a deficiency of $66,666.84 in petitioners' income tax for the taxable year ended June 30, 1962.

The sole issue is whether petitioner Joe D. Branham "disposed of" certain installments due him under a promissory note within the purview of section 453(d)(1).1

FINDINGS OF FACT

Some of the facts were stipulated. The stipulation of facts, together with the exhibits attached thereto...

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