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RYAN v. COMMISSIONER

Docket Nos. 42105-84, 42203-84, 191-85.

54 T.C.M. 1503 (1988)

T.C. Memo. 1988-12

Thomas A. Ryan and Patricia J. Ryan, et al. v. Commissioner.

United States Tax Court.

Filed January 7, 1988.

Attorney(s) appearing for the Case

Lee N. Johnson, 400 Second Ave. S., Minneapolis, Minn., for the petitioners. Jack A. Forsberg, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent, in statutory notices of deficiency dated October 5, 1984, determined deficiencies in petitioners' income taxes for 1978 as follows:

Ryan ....................   $34,563.00
O'Brien .................    25,313.61
Lamm ....................    11,847.82

This action concerns the correct period for realizing income upon the foreclosure of property subject to nonrecourse...

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