Memorandum Findings of Fact and Opinion
SWIFT, Judge:
Respondent determined a deficiency of $26,818 in petitioners' joint Federal income tax for 1984. The sole issue for decision is whether, as respondent contends, a partnership (in which decedent, Thomas F. Wilkinson, owned an interest) is to be treated as having elected out of the installment method of accounting with respect to income from the sale of a building.
Unless otherwise indicated, all...
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