VAN GRAAFEILAND, Circuit Judge:
Andrew Crispo Gallery, Inc. ("the Gallery") appeals from a decision of the United States Tax Court (Cohen, J.) holding that the Gallery was not entitled to use the installment method of reporting income to defer recognition of profits derived from a sale of paintings seized and sold at auction by the Internal Revenue Service ("IRS"). This is the second time the Gallery has been before us seeking relief from adverse decisions of the...
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