In 1968, petitioner Richard Rosenblatt sold stock, in a closely held corporation, with respect to which, for personal income tax purposes, he elected to report the resulting long term capital gain on the installment basis. The 1972 installment, taxed by the Income Tax Bureau at the rate of tax in effect under the laws of 1972, resulted in a deficiency of $36,950.20, with interest thereon. Petitioners contend that the gain was realized in 1968, hence the 1968 tax rate applies...
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