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ESTATE OF ROGERS v. COMMISSIONER

Docket No. 107817.

1 T.C. 629 (1943)

ESTATE OF HENRY H. ROGERS, DECEASED, ALBERT STICKNEY AND CENTRAL HANOVER BANK AND TRUST COMPANY, AS SURVIVING EXECUTORS OF THE LAST WILL AND TESTAMENT OF HENRY H. ROGERS, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 23, 1943.

Attorney(s) appearing for the Case

Theodore Pearson, Esq., for the petitioners.

T. H. Lewis, Jr., Esq., for the respondent.

OPINION.

ARUNDELL, Judge:

The Commissioner's determination that a sale was not reportable on the installment basis gave rise to the presently contested deficiency of $790,125.75 in income tax for 1937. If it is held that this determination was erroneous, the Commissioner by amended answer presents the alternative view that certain of the installment obligations were disposed of by petitioners during the tax year, the gain therefrom resulting in a...

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