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TRIVETT v. COMMISSIONER

Docket No. 2113-75.

36 T.C.M. 675 (1977)

T.C. Memo. 1977-161

Ulysses G. Trivett, Jr., and Violet W. Trivett v. Commissioner.

United States Tax Court.

Filed May 31, 1977.

Attorney(s) appearing for the Case

William I. Althen and George D. Webster, Suite 1000, 1747 Pennsylvania Ave., N.W., Washington, D.C., for the petitioners. Robert B. Nadler, for the respondent.

Memorandum Opinion

DAWSON, Chief Judge:

Respondent determined a deficiency of $95,600.56 in petitioners' Federal income tax for the year 1969.

Several adjustments have been conceded by the parties. The issues remaining for our decision are (1) whether petitioners are entitled to report the proceeds from the sale of a Dairy Queen franchise on the installment method; (2) whether petitioners are entitled to a loss of $25,164 from the Garden-Vale Apartments...

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