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HERNDON v. COMMISSIONER

Docket No. 4262-80.

51 T.C.M. 1144 (1986)

T.C. Memo. 1986-230

Kenneth D. Herndon and Tonya Herndon v. Commissioner.

United States Tax Court.

Filed June 9, 1986.

Attorney(s) appearing for the Case

J.R. Blumrosen, 510 Texas Commerce Bank Bldg., Lubbock, Tex., for the petitioners. A. Shawn Noonan, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

The Commissioner determined deficiencies in petitioners' Federal income taxes for their taxable year 1973 in the amount of $8,322.71 and for their taxable year 1974 in the amount of $800.22. After concessions, the only remaining issue in this case is whether the proceeds from the sale of petitioners' cotton in the amount of $33,858.91 is income to petitioners in the calendar tax year 1973 or 1974.

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