SPIVEY v. COMMISSIONER

Docket No. 91114.

40 T.C. 1051 (1963)

NATHAN C. SPIVEY AND ELIZABETH P. SPIVEY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 30, 1963.


Attorney(s) appearing for the Case

H. Brice Graves, for the petitioners.

Douglas O. Tice, Jr., for the respondent.


FISHER, Judge:

This proceeding involves a deficiency in petitioners' 1957 income tax of $15,389.51.

The only question in issue is whether petitioners are taxable on the full amount of their gain on the sale of their farmland and residence in 1957, the year of the sale, or whether they are entitled to report their gain in part on the installment basis.

FINDINGS OF FACT

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

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