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STILES v. COMMISSIONER

Docket No. 3886-76.

69 T.C. 558 (1978)

FRED M. STILES AND JEAN M. STILES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 10, 1978.

Attorney(s) appearing for the Case

John D. Colliander, for the petitioners.

John O. Tannenbaum, for the respondent.

OPINION

TIETJENS, Judge:

Respondent determined a deficiency of $193,910.67 in petitioners' Federal income taxes for 1972. The issues are whether the redemption of petitioners' corporate stock qualifies as an installment sale under section 453,1 and, if so, whether petitioners can now change to a cost recovery method of accounting after electing to report under the installment method.

This case was fully stipulated...

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