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KUTSUNAI v. COMMISSIONER

Docket No. 15964-81.

45 T.C.M. 1179 (1983)

T.C. Memo. 1983-182

Akira Kutsunai and Ruth T. Kutsunai v. Commissioner.

United States Tax Court.

Filed April 4, 1983.

Attorney(s) appearing for the Case

Herbert T. Ikazaki and Richard T. Kaneko, 1412 Amfac Bldg., Honolulu, Hawaii, for the petitioners. Arthur A. Oshiro, for the respondent.

Memorandum Opinion

FAY, Judge:

Respondent determined a deficiency of $6,228 in petitioners' 1976 Federal income tax. After concessions, the issue is whether petitioners may continue to report on the installment basis their pro rata share of a partnership's settlement proceeds arising out of the sale of certain property.

All the facts are stipulated and found accordingly.

Petitioners, Akira and Ruth T. Kutsunai, resided in Honolulu, Hawaii...

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