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WRENN v. COMMISSIONER

Docket No. 7218-75.

67 T.C. 576 (1976)

PHILIP W. WRENN AND DOROTHY W. WRENN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 23, 1976.

Attorney(s) appearing for the Case

Roy D. Lambert, for the petitioners.

Leo A. Reinikka, Jr., for the respondent.

OPINION

DAWSON, Chief Judge:

Respondent determined a deficiency of $56,387 in petitioners' Federal income tax for calendar year 1973. The sole issue presented for decision is whether gain realized by petitioner Philip W. Wrenn from the sale of common stocks to his wife may be reported in annual installments pursuant to the provisions of section 453, I.R.C. 1954.1

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