GILBERT v. COMMISSIONER

Docket No. 50459.

25 T.C. 81 (1955)

FRANK H. GILBERT AND HAZEL P. PETERSON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 24, 1955.


Attorney(s) appearing for the Case

Louis McClennen, Esq., for the petitioners.

R. E. Maiden, Jr., Esq., for the respondent.


OPINION.

FISHER, Judge:

The respondent determined deficiencies in income tax against the petitioners for the taxable year 1949 in the amount of $47,603.77. The petitioners have asserted a claim for overpayment in the sum of $1,129.44. During the year 1949, petitioners were husband and wife and filed a joint income tax return for that year.

The questions presented are (1) whether or not petitioners may report the sale of stock on the installment...

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