Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined a deficiency in the income tax of petitioner for the taxable year 1963 in the amount of $4,173.39. Certain adjustments made by respondent in his determination of deficiency are not at issue under the pleadings. The sole issue before the Court is whether respondent has erred in disallowing the use of the installment method of reporting gain on petitioner's sale of a motel...
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