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HANSEL v. COMMISSIONER

Docket No. 5377-79

42 T.C.M. 922 (1981)

T.C. Memo. 1981-472

Paul R. and Helena J. Hansel v. Commissioner.

United States Tax Court.

Filed August 31, 1981.

Attorney(s) appearing for the Case

John L. Kuehnle, for the petitioners. Christy M. Pendley, for the respondent.

Memorandum Opinion

HALL, Judge:

Respondent determined a $1,684 deficiency in petitioners' 1976 income tax. The issues for decision are: (1) whether certain 1976 amendments to sections 561 and 57 (the minimum tax provisions of the Code)2 can be applied to a capital gain recognized in 1976, but attributable to a 1975 transaction which the taxpayers elected to report under the installment method (section...

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