WILBUR, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the taxable years 1976 and 1977 in the amounts of $12,442 and $429, respectively. After concessions, the sole issue presented for our decision is whether petitioner is entitled to elect to report the sale of realty in 1976 under the installment method pursuant to section 453 of the Internal Revenue Code of 1954,
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