HOLMES v. COMMISSIONER

Docket No. 677-70SC.

55 T.C. 53 (1970)

CARL F. HOLMES AND KATHLEEN E. HOLMES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 19, 1970.


Attorney(s) appearing for the Case

Carl F. Holmes, pro se.

Robert D. Forrester and Jeffrey E. Boly, for the respondent.


DRENNEN, Judge:

Respondent determined a deficiency of $693.89 in petitioner's Federal income tax for the taxable year 1966.

Due to concessions by petitioners, the only issue for our decision is whether a promissory note of a third party received by petitioners in partial payment for the sale of real property is an "indebtedness of the purchaser" within the meaning of section 453 (b) (2), I.R.C. 1954.1

FINDINGS OF...

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