United States Tax Court August 7, 1973, Docket No. 424-71 (Warren Jones Co. v. Commissioner)

lead-opinion

Dawson, Judge.*

Respondent determined a deficiency in petitioner’s Federal income tax in the amount of $2,523.94 for the taxable year ended October 31,1968. The only issue to be decided is whether the petitioner, a cash basis taxpayer, realized income in 1968 upon the sale of appreciated property in return for a deferred-payment obligation under a real estate contract.