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APPLEGATE v. COMMISSIONER

Docket No. 12721-88.

94 T.C. 696 (1990)

CALVIN P. APPLEGATE AND IRMA APPLEGATE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 16, 1990.

Attorney(s) appearing for the Case

Ronald K. Fellheimer, for the petitioners.*

Michael W. Bitner, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1984 in the amount of $240,955. After concessions, the issues for decision are whether the sales of grain received pursuant to crop share leases qualified for reporting on the installment method under section 4531 and whether the payments received at the time of execution of the contracts for such sales...

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