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HUTCHISON v. COMMISSIONER

Docket No. 2373-78.

42 T.C.M. 1089 (1981)

T.C. Memo. 1981-513

Frank Hutchison and Betty Hutchison v. Commissioner.

United States Tax Court.

Filed September 15, 1981.

Attorney(s) appearing for the Case

Kenneth R. Mourton, One McIlroy Plaza, Fayetteville, Ark., for the petitioners. Charles L. McReynolds, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined deficiencies of $4,298.53 and $86,326.93 in petitioners' Federal income tax for 1974 and 1975 respectively. Due to concessions by petitioners, the sole issue for our determination is whether the excess of mortgage principal over the basis of an apartment complex sold in 1971 by petitioner-husband should be treated as an installment payment...

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