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FLOWER v. COMMISSIONER

Docket No. 7432-70.

61 T.C. 140 (1973)

HARRY M. FLOWER AND GAIL FLOWER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 31, 1973.

Attorney(s) appearing for the Case

Morgan Hunter, for the petitioners.

Robert H. Jones, for the respondent.

DRENNEN, Judge:

Respondent determined deficiencies in petitioners' Federal income tax as follows:

Year                             Deficiency

1965 ------------------------ $3,415.34
1966 ------------------------  5,057.73
1967 ------------------------  4,780.37

The issues for decision are: (1) Whether petitioners are entitled to capital gains treatment on payments received under a contract which purported to terminate...

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