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PITYO v. COMMISSIONER

Docket No. 7445-76.

70 T.C. 225 (1978)

WILLIAM D. PITYO AND PATRICIA A. PITYO, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 15, 1978.

Attorney(s) appearing for the Case

Sherwin P. Simmons, William Kalish, Merritt A. Gardner, John J. Trenam, and Rolfe D. Duggar, for the petitioners.

Stuart B. Kalb, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in petitioners' joint Federal income tax for 1972 in the amount of $151,549. As a result of concessions by petitioners, the sole issue remaining for decision is whether petitioners are entitled to report the gain on the sale of certain securities on the installment method under section 453.1

FINDINGS OF FACT

Petitioners William D. Pityo and Patricia A. Pityo...

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