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MONSON v. COMMISSIONER

Docket No. 11432-80.

79 T.C. 827 (1982)

CLARENCE J. MONSON AND MILDRED R. MONSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 18, 1982.

Attorney(s) appearing for the Case

Richard L. Kintz and Paul R. Wassenaar, for the petitioners. M. K. Mortensen, for the respondent.

SCOTT, Judge:

Respondent determined a deficiency in petitioners' income tax for the calendar year 1976 in the amount of $71,296. By amendment to his answer, respondent claimed on an alternative basis an increase in the deficiency determined to $87,236.

The issues for decision are: (1) Whether petitioners are entitled to report the gain on the sale by Mr. Monson of 259 shares of stock of Monson Truck Co. on an installment basis under section 453(b)

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