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PORTERFIELD v. COMMISSIONER

Docket No. 1504-77.

73 T.C. 91 (1979)

C. J. PORTERFIELD AND IRENE PORTERFIELD, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 15, 1979.

Attorney(s) appearing for the Case

Frank L. Scofield, for the petitioners.

James N. Mullen, for the respondent.

SIMPSON, Judge:

The Commissioner determined a deficiency of $79,903.69 in the petitioners' Federal income tax for 1972. The petitioners have conceded several issues; the sole issue remaining for decision is whether the petitioners were entitled to use the installment method of section 453 of the Internal Revenue Code of 19541 to report the gain on the sale of a ranch. The resolution of such issue turns on whether certain certificates...

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