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ESTATE OF SILVERMAN v. COMMISSIONER

Docket No. 21209-88.

98 T.C. 54 (1992)

ESTATE OF MOSE SILVERMAN, DECEASED, ROSE SILVERMAN, EXECUTRIX, AND ROSE SILVERMAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 21, 1992.

Attorney(s) appearing for the Case

William Rochester, for petitioners.

Steven J. Foster, for respondent.

RUWE, Judge:

Respondent determined a deficiency in petitioners' Federal income taxes for 1982 in the amount of $98,196. The issue for decision is whether petitioners are entitled to use the installment method to report the gain on exchange of their shares of stock in a savings and loan association for savings accounts of another savings and loan association.

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. The stipulation...

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