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RICKEY v. COMMISSIONER

Docket No. 5426-67.

54 T.C. 680 (1970)

JOHN H. RICKEY AND LORRAINE C. RICKEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 31, 1970.

Attorney(s) appearing for the Case

Paul E. Anderson, C. Henry Veit, and William E. Anderson, Jr., for the petitioners.

Martin A. Schainbaum and Edward B. Simpson, for the respondent.

DRENNEN, Judge:

Respondent determined deficiencies in petitioners' income tax for the taxable years 1962 and 1964 of $224,996.07 and $12,173.94, respectively.

Due to concessions by both parties, the issues remaining for our decision are: (1) Whether petitioners are entitled to report the gain from the sale in the years 1962 of stock of two corporations on the installment method of accounting as provided by section 453,

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