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WATSON v. COMMISSIONER OF INTERNAL REVENUE SERVICE

No. 78-1770.

613 F.2d 594 (1980)

H. N. WATSON, Jr., and wife, Shirley Watson, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

March 14, 1980.

Attorney(s) appearing for the Case

J. R. Blumrosen, Myrtle D. McDonald, Lubbock, Tex., for petitioners-appellants.

M. Carr Ferguson, Asst. Atty. Gen., Richard W. Perkins, Atty., Gilbert E. Andrews, Act. Chief, Tax Div., U. S. Dept. of Justice, Lester Stein, Act. Chief Counsel, IRS, Washington, D. C., for respondent-appellee.

Before GEWIN, RUBIN and SAM D. JOHNSON, Circuit Judges.

SAM D. JOHNSON, Circuit Judge:

H. N. (Sonny) and Shirley Watson are taxpayers utilizing the cash receipts and disbursements method of accounting. In November, 1973 they sold a number of bales of cotton pursuant to an arrangement called a deferred payment agreement. In return they received an irrevocable banker's letter of credit in the amount of $42,146.51. The bank's letter of credit guaranteed it would accept and honor this instrument in January, 1974. On January...

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