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WILSON v. COMMISSIONER

Docket No. 6483-76.

40 T.C.M. 835 (1980)

T.C. Memo. 1980-288

Stanley E. Wilson and Christine Wilson v. Commissioner.

United States Tax Court.

Filed August 4, 1980.

Attorney(s) appearing for the Case

Allan Howeth and Kirk R. Manning, 1800 First Nat'l Bank Bldg., Fort Worth, Tex. for the petitioners. H. Steven New, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined deficiencies in petitioners' Federal income tax for the taxable years 1972 and 1973 in the respective amounts of $58,571.45 and $1,194.07.

Due to concessions of the parties, the sole issue for our decision is whether petitioners are entitled to utilize the installment method under section 453, Internal Revenue Code of...

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