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REAVER v. COMMISSIONER

Docket No. 93589.

42 T.C. 72 (1964)

JOHN P. REAVER AND OPAL P. REAVER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 13, 1964.

Attorney(s) appearing for the Case

Hugh R. Dowling and John W. Mooers, for the petitioners.

Louis J. DeReuil, for the respondent.

DRENNEN, Judge:

Respondent determined a deficiency in petitioners' income tax for the year 1958 in the amount of $40,199.98, and in additions to tax under sections 6653(a) and 6654(a), I.R.C. 1954,1 in the respective amounts of $2,010 and $31.23.

The primary issue for decision is whether petitioners are entitled to return gain and pay tax on their gain from the sale of a 35-acre tract of land in 1958 on the installment method...

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