SCHNIERS v. COMMISSIONER

Docket No. 10225-75.

69 T.C. 511 (1977)

CHARLES B. SCHNIERS AND DOROTHY M. SCHNIERS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 27, 1977.


Attorney(s) appearing for the Case

William Norton Baker and Karl Norman Clifford, for the petitioners.

Charles R. Billings, for the respondent.


FEATHERSTON, Judge:

Respondent determined a deficiency of $22,000.11 in petitioners' Federal income tax for 1973. Concessions having been made by petitioners, the sole issue presented for decision is whether petitioners realized income of $45,376.48, representing the proceeds of the sale of their cotton crop, in 1973 even though they did not receive checks in payment for the cotton until 1974.

FINDINGS OF FACT

Petitioners Charles B. Schniers...

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