§453 — Installment method

261 cases·82 followed·35 distinguished·9 questioned·4 criticized·1 overruled·130 cited—31% support

Statute Text — 26 U.S.C. §453

(a)General rule

Except as otherwise provided in this section, income from an installment sale shall be taken into account for purposes of this title under the installment method.

(b)Installment sale defined

For purposes of this section—

(1)In general

The term “installment sale” means a disposition of property where at least 1 payment is to be received after the close of the taxable year in which the disposition occurs.

(2)Exceptions

The term “installment sale” does not include—

(A)Dealer dispositions

Any dealer disposition (as defined in subsection (l)).

(B)Inventories of personal property

A disposition of personal property of a kind which is required to be included in the inventory of the taxpayer if on hand at the close of the taxable year.

(c)Installment method defined

For purposes of this section, the term “installment method” means a method under which the income recognized for any taxable year from a disposition is that proportion of the payments received in that year which the gross profit (realized or to be realized when payment is completed) bears to the total contract price.

(d)Election out

(1)In general

Subsection (a) shall not apply to any disposition if the taxpayer elects to have subsection (a) not apply to such disposition.

(2)Time and manner for making election

Except as otherwise provided by regulations, an election under paragraph (1) with respect to a disposition may be made only on or before the due date prescribed by law (including extensions) for filing the taxpayer’s return of the tax imposed by this chapter for the taxable year in which the disposition occurs. Such an election shall be made in the manner prescribed by regulations.

(3)Election revocable only with consent

An election under paragraph (1) with respect to any disposition may be revoked only with the consent of the Secretary.

(e)Second dispositions by related persons

(1)In general

If—

(A)

any person disposes of property to a related person (hereinafter in this subsection referred to as the “first disposition”), and

(B)

before the person making the first disposition receives all payments with respect to such disposition, the related person disposes of the property (hereinafter in this subsection referred to as the “second disposition”),

then, for purposes of this section, the amount realized with respect to such second disposition shall be treated as received at the time of the second disposition by the person making the first disposition.

(2)2-year cutoff for property other than marketable securities

(A)In general

Except in the case of marketable securities, paragraph (1) shall apply only if the date of the second disposition is not more than 2 years after the date of the first disposition.

(B)Substantial diminishing of risk of ownership

The running of the 2-year period set forth in subparagraph (A) shall be suspended with respect to any property for any period during which the related person’s risk of loss with respect to the property is substantially diminished by—

(i)

the holding of a put with respect to such property (or similar property),

(ii)

the holding by another person of a right to acquire the property, or

(iii)

a short sale or any other transaction.

(3)Limitation on amount treated as received

The amount treated for any taxable year as received by the person making the first disposition by reason of paragraph (1) shall not exceed the excess of—

(A)

the lesser of—

(i)

the total amount realized with respect to any second disposition of the property occurring before the close of the taxable year, or

(ii)

the total contract price for the first disposition, over

(B)

the sum of—

(i)

the aggregate amount of payments received with respect to the first disposition before the close of such year, plus

(ii)

the aggregate amount treated as received with respect to the first disposition for prior taxable years by reason of this subsection.

(4)Fair market value where disposition is not sale or exchange

For purposes of this subsection, if the second disposition is not a sale or exchange, an amount equal to the fair market value of the property disposed of shall be substituted for the amount realized.

(5)Later payments treated as receipt of tax paid amounts

If paragraph (1) applies for any taxable year, payments received in subsequent taxable years by the person making the first disposition shall not be treated as the receipt of payments with respect to the first disposition to the extent that the aggregate of such payments does not exceed the amount treated as received by reason of paragraph (1).

(6)Exception for certain dispositions

For purposes of this subsection—

(A)Reacquisitions of stock by issuing corporation not treated as first dispositions

Any sale or exchange of stock to the issuing corporation shall not be treated as a first disposition.

(B)Involuntary conversions not treated as second dispositions

A compulsory or involuntary conversion (within the meaning of section 1033) and any transfer thereafter shall not be treated as a second disposition if the first disposition occurred before the threat or imminence of the conversion.

(C)Dispositions after death

Any transfer after the earlier of—

(i)

the death of the person making the first disposition, or

(ii)

the death of the person acquiring the property in the first disposition,

and any transfer thereafter shall not be treated as a second disposition.

(7)Exception where tax avoidance not a principal purpose

This subsection shall not apply to a second disposition (and any transfer thereafter) if it is established to the satisfaction of the Secretary that neither the first disposition nor the second disposition had as one of its principal purposes the avoidance of Federal income tax.

(8)Extension of statute of limitations

The period for assessing a deficiency with respect to a first disposition (to the extent such deficiency is attributable to the application of this subsection) shall not expire before the day which is 2 years after the date on which the person making the first disposition furnishes (in such manner as the Secretary may by regulations prescribe) a notice that there was a second disposition of the property to which this subsection may have applied. Such deficiency may be assessed notwithstanding the provisions of any law or rule of law which would otherwise prevent such assessment.

(f)Definitions and special rules

For purposes of this section—

(1)Related person

Except for purposes of subsections (g) and (h), the term “related person” means—

(A)

a person whose stock would be attributed under section 318(a) (other than paragraph (4) thereof) to the person first disposing of the property, or

(B)

a person who bears a relationship described in section 267(b) to the person first disposing of the property.

(2)Marketable securities

The term “marketable securities” means any security for which, as of the date of the disposition, there was a market on an established securities market or otherwise.

(3)Payment

Except as provided in paragraph (4), the term “payment” does not include the receipt of evidences of indebtedness of the person acquiring the property (whether or not payment of such indebtedness is guaranteed by another person).

(4)Purchaser evidences of indebtedness payable on demand or readily tradable

Receipt of a bond or other evidence of indebtedness which—

(A)

is payable on demand, or

(B)

is readily tradable,

shall be treated as receipt of payment.

(5)Readily tradable defined

For purposes of paragraph (4), the term “readily tradable” means a bond or other evidence of indebtedness which is issued—

(A)

with interest coupons attached or in registered form (other than one in registered form which the taxpayer establishes will not be readily tradable in an established securities market), or

(B)

in any other form designed to render such bond or other evidence of indebtedness readily tradable in an established securities market.

(6)Like-kind exchanges

In the case of any exchange described in section 1031(b)—

(A)

the total contract price shall be reduced to take into account the amount of any property permitted to be received in such exchange without recognition of gain,

(B)

the gross profit from such exchange shall be reduced to take into account any amount not recognized by reason of section 1031(b), and

(C)

the term “payment”, when used in any provision of this section other than subsection (b)(1), shall not include any property permitted to be received in such exchange without recognition of gain.

Similar rules shall apply in the case of an exchange which is described in section 356(a) and is not treated as a dividend.

(7)Depreciable property

The term “depreciable property” means property of a character which (in the hands of the transferee) is subject to the allowance for depreciation provided in section 167.

(8)Payments to be received defined

The term “payments to be received” includes—

(A)

the aggregate amount of all payments which are not contingent as to amount, and

(B)

the fair market value of any payments which are contingent as to amount.

(g)Sale of depreciable property to controlled entity

(1)In general

In the case of an installment sale of depreciable property between related persons—

(A)

subsection (a) shall not apply,

(B)

for purposes of this title—

(i)

except as provided in clause (ii), all payments to be received shall be treated as received in the year of the disposition, and

(ii)

in the case of any payments which are contingent as to the amount but with respect to which the fair market value may not be reasonably ascertained, the basis shall be recovered ratably, and

(C)

the purchaser may not increase the basis of any property acquired in such sale by any amount before the time such amount is includible in the gross income of the seller.

(2)Exception where tax avoidance not a principal purpose

Paragraph (1) shall not apply if it is established to the satisfaction of the Secretary that the disposition did not have as one of its principal purposes the avoidance of Federal income tax.

(3)Related persons

For purposes of this subsection, the term “related persons” has the meaning given to such term by section 1239(b), except that such term shall include 2 or more partnerships having a relationship to each other described in section 707(b)(1)(B).

(h)Use of installment method by shareholders in certain liquidations

(1)Receipt of obligations not treated as receipt of payment

(A)In general

If, in a liquidation to which section 331 applies, the shareholder receives (in exchange for the shareholder’s stock) an installment obligation acquired in respect of a sale or exchange by the corporation during the 12-month period beginning on the date a plan of complete liquidation is adopted and the liquidation is completed during such 12-month period, then, for purposes of this section, the receipt of payments under such obligation (but not the receipt of such obligation) by the shareholder shall be treated as the receipt of payment for the stock.

(B)Obligations attributable to sale of inventory must result from bulk sale

Subparagraph (A) shall not apply to an installment obligation acquired in respect of a sale or exchange of—

(i)

stock in trade of the corporation,

(ii)

other property of a kind which would properly be included in the inventory of the corporation if on hand at the close of the taxable year, and

(iii)

property held by the corporation primarily for sale to customers in the ordinary course of its trade or business,

unless such sale or exchange is to 1 person in 1 transaction and involves substantially all of such property attributable to a trade or business of the corporation.

(C)Special rule where obligor and shareholder are related persons

If the obligor of any installment obligation and the shareholder are married to each other or are related persons (within the meaning of section 1239(b)), to the extent such installment obligation is attributable to the disposition by the corporation of depreciable property—

(i)

subparagraph (A) shall not apply to such obligation, and

(ii)

for purposes of this title, all payments to be received by the shareholder shall be deemed received in the year the shareholder receives the obligation.

(D)Coordination with subsection (e)(1)(A)

For purposes of subsection (e)(1)(A), disposition of property by the corporation shall be treated also as disposition of such property by the shareholder.

(E)Sales by liquidating subsidiaries

For purposes of subparagraph (A), in the case of a controlling corporate shareholder (within the meaning of section 368(c)) of a selling corporation, an obligation acquired in respect of a sale or exchange by the selling corporation shall be treated as so acquired by such controlling corporate shareholder. The preceding sentence shall be applied successively to each controlling corporate shareholder above such controlling corporate shareholder.

(2)Distributions received in more than 1 taxable year of shareholder

If—

(A)

paragraph (1) applies with respect to any installment obligation received by a shareholder from a corporation, and

(B)

by reason of the liquidation such shareholder receives property in more than 1 taxable year,

then, on completion of the liquidation, basis previously allocated to property so received shall be reallocated for all such taxable years so that the shareholder’s basis in the stock of the corporation is properly allocated among all property received by such shareholder in such liquidation.

(i)Recognition of recapture income in year of disposition

(1)In general

In the case of any installment sale of property to which subsection (a) applies—

(A)

notwithstanding subsection (a), any recapture income shall be recognized in the year of the disposition, and

(B)

any gain in excess of the recapture income shall be taken into account under the installment method.

(2)Recapture income

For purposes of paragraph (1), the term “recapture income” means, with respect to any installment sale, the aggregate amount which would be treated as ordinary income under section 1245 or 1250 (or so much of section 751 as relates to section 1245 or 1250) for the taxable year of the disposition if all payments to be received were received in the taxable year of disposition.

(j)Regulations

(1)In general

The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the provisions of this section.

(2)Selling price not readily ascertainable

The regulations prescribed under paragraph (1) shall include regulations providing for ratable basis recovery in transactions where the gross profit or the total contract price (or both) cannot be readily ascertained.

(k)Current inclusion in case of revolving credit plans, etc.

In the case of—

(1)

any disposition of personal property under a revolving credit plan, or

(2)

any installment obligation arising out of a sale of—

(A)

stock or securities which are traded on an established securities market, or

(B)

to the extent provided in regulations, property (other than stock or securities) of a kind regularly traded on an established market,

subsection (a) shall not apply, and, for purposes of this title, all payments to be received shall be treated as received in the year of disposition. The Secretary may provide for the application of this subsection in whole or in part for transactions in which the rules of this subsection otherwise would be avoided through the use of related parties, pass-thru entities, or intermediaries.

(l)Dealer dispositions

For purposes of subsection (b)(2)(A)—

(1)In general

The term “dealer disposition” means any of the following dispositions:

(A)Personal property

Any disposition of personal property by a person who regularly sells or otherwise disposes of personal property of the same type on the installment plan.

(B)Real property

Any disposition of real property which is held by the taxpayer for sale to customers in the ordinary course of the taxpayer’s trade or business.

(2)Exceptions

The term “dealer disposition” does not include—

(A)Farm property

The disposition on the installment plan of any property used or produced in the trade or business of farming (within the meaning of section 2032A(e)(4) or (5)).

(B)Timeshares and residential lots

(i)In general

Any dispositions described in clause (ii) on the installment plan if the taxpayer elects to have paragraph (3) apply to any installment obligations which arise from such dispositions. An election under this paragraph shall not apply with respect to an installment obligation which is guaranteed by any person other than an individual.

(ii)Dispositions to which subparagraph applies

A disposition is described in this clause if it is a disposition in the ordinary course of the taxpayer’s trade or business to an individual of—

(I)

a timeshare right to use or a timeshare ownership interest in residential real property for not more than 6 weeks per year, or a right to use specified campgrounds for recreational purposes, or

(II)

any residential lot, but only if the taxpayer (or any related person) is not to make any improvements with respect to such lot.

For purposes of subclause (I), a timeshare right to use (or timeshare ownership interest in) property held by the spouse, children, grandchildren, or parents of an individual shall be treated as held by such individual.

(C)Carrying charges or interest

Any carrying charges or interest with respect to a disposition described in subparagraph (A) or (B) which are added on the books of account of the seller to the established cash selling price of the property shall be included in the total contract price of the property and, if such charges or interest are not so included, any payments received shall be treated as applying first against such carrying charges or interest.

(3)Payment of interest on timeshares and residential lots

(A)In general

In the case of any installment obligation to which paragraph (2)(B) applies, the tax imposed by this chapter for any taxable year for which payment is received on such obligation shall be increased by the amount of interest determined in the manner provided under subparagraph (B).

(B)Computation of interest

(i)In general

The amount of interest referred to in subparagraph (A) for any taxable year shall be determined—

(I)

on the amount of the tax for such taxable year which is attributable to the payments received during such taxable year on installment obligations to which this subsection applies,

(II)

for the period beginning on the date of sale, and ending on the date such payment is received, and

(III)

by using the applicable Federal rate under section 1274 (without regard to subsection (d)(2) thereof) in effect at the time of the sale compounded semiannually.

(ii)Interest not taken into account

For purposes of clause (i), the portion of any tax attributable to the receipt of any payment shall be determined without regard to any interest imposed under subparagraph (A).

(iii)Taxable year of sale

No interest shall be determined for any payment received in the taxable year of the disposition from which the installment obligation arises.

(C)Treatment as interest

Any amount payable under this paragraph shall be taken into account in computing the amount of any deduction allowable to the taxpayer for interest paid or accrued during such taxable year.

Treasury Regulations

Treas. Reg. §Treas. Reg. §1.453-11 Installment obligations received from a liquidating corporation
Treas. Reg. §Treas. Reg. §1.453-11(a) In general—(1) Overview.
Treas. Reg. §Treas. Reg. §1.453-11(b) Qualifying shareholder.
Treas. Reg. §Treas. Reg. §1.453-11(c) Qualifying installment obligation—(1) In general.
Treas. Reg. §Treas. Reg. §1.453-11(d) Liquidating distributions received in more than one taxable year.
Treas. Reg. §Treas. Reg. §1.453-11(e) Effective date.
Treas. Reg. §Treas. Reg. §1.453-12 Allocation of unrecaptured section 1250 gain reported on the installment method
Treas. Reg. §Treas. Reg. §1.453-12(a) General rule.
Treas. Reg. §Treas. Reg. §1.453-12(b) Installment payments from sales before May 7, 1997.
Treas. Reg. §Treas. Reg. §1.453-12(c) Installment payments received after May 6, 1997, and on or before August 23, 1999.
Treas. Reg. §Treas. Reg. §1.453-12(d) Examples.
Treas. Reg. §Treas. Reg. §1.453-12(e) Effective date.
Treas. Reg. §Treas. Reg. §1.453-3 Purchaser evidences of indebtedness payable on demand or readily tradable
Treas. Reg. §Treas. Reg. §1.453-3(a) In general.
Treas. Reg. §Treas. Reg. §1.453-3(b) Treatment as payment.
Treas. Reg. §Treas. Reg. §1.453-3(c) Payable on demand.
Treas. Reg. §Treas. Reg. §1.453-3(d) Designed to be readily tradable in an established securities market—(1) In general.
Treas. Reg. §Treas. Reg. §1.453-3(e) Special rule for convertible securities—(1) General rule.
Treas. Reg. §Treas. Reg. §1.453-3(f) Effective date.
Treas. Reg. §Treas. Reg. §1.453-3(i) §1.453-3(i)
Treas. Reg. §Treas. Reg. §1.453-9 Gain or loss on disposition of installment obligations
Treas. Reg. §Treas. Reg. §1.453-9(a) In general.
Treas. Reg. §Treas. Reg. §1.453-9(b) Computation of gain or loss.
Treas. Reg. §Treas. Reg. §1.453-9(c) Disposition from which no gain or loss is recognized.
Treas. Reg. §Treas. Reg. §1.453-9(d) Carryover of installment method.

261 Citing Cases

DIST. D. G. & Nell R. Smalley, Petitioner 116 T.C. No. 29 · 2001

Commissioner, supra, unlike the sec. 1031 regulations applicable here, contained no explicit coordination with the installment sale provisions of sec. 453.

DIST. William A. Read, Petitioner 114 T.C. No. 2 · 2000

453 does not apply to the receipt of a distribution taxed as a dividend under sec.

QUEST. King Solarman, Inc., Petitioner · 2019

We need not decide whether petitioner should be viewed as having elected installment treatment, however, because the statute precludes use ofthe install- ¹°Even ifall the events were thought to have occurred to fix petitioner's warranty liability, it has supplied no rational basis for determining how that liabil- ity

CRIT. Joyner Family Limited Partnership, Gary Joyner Revocable Trust, A Partner Other Than the Tax Matters Partner; Janel Joyner Revocable Trust, A Partner Other Than the Tax Matters Partner and Joyner Investment Company, Inc., Tax Matters Partner, Petitioners · 2019

Furthermore, we do not agree with the characterization ofJFLP's method as a hybrid method, a position petitioners assert for the first time in their briefs.

FOLLOWED Annie Berman, Petitioner 163 T.C. No. 1 · 2024

Section 453 provides that “[e]xcept as otherwise provided in this section, income from an installment sale shall be taken into account for purposes of this title under the installment method.” § 453(a) (emphasis added).

FOLLOWED Herb Vest, Petitioner · 2016

Section 453 provides an exception to this rule, allowing income from an installment sale to be reported as payments are received.

FOLLOWED Herb Vest, Petitioner · 2016

Section 453 provides an exception to this rule, allowing income from an installment sale to be reported as payments are received.

FOLLOWED Herb Vest, Petitioner · 2016

Section 453 provides an exception to this rule, allowing income from an installment sale to be reported as payments are received.

FOLLOWED TG Missouri Corporation f.k.a. TG (U.S.A.) Corporation, a Missouri Corporation, Petitioners 133 T.C. No. 13 · 2009

Because we hold that the production molds petitioner sold to customers are not of a character subject to an 32 - allowance under section 167, the limitation applicable to costs .

FOLLOWED Robert W. & Janet L. Carlson, Petitioner 112 T.C. No. 17 · 1999

Respondent argues that the interest paid by petitioner as a shareholder of an S corporation, pursuant to section 453(l)(3), is nondeductible personal interest under section 163(h).

Alexandra S. Yankwich, f.k.a. Alexandra Y. Capps, Petitioners T.C. Memo. 2002-37 · 2002

Section 453B(a) provides that if an installment obligation is satisfied for less than face value, distributed, transmitted, sold, or otherwise disposed of, gain or loss shall result. Section 453B(a) does not apply to transfers of installment obligations between spouses incident to a divorce as described in section 1041(a). Sec. 453B(g)(1). In that

Smalley v. Commissioner 116 T.C. 450 · 2001

Coordination of Section 1031 Regulations and Section 453 The section 1031 regulations state: “Except as otherwise provided, the amount of gain or loss recognized * * * in a deferred exchange is determined by applying the rules of section 1031 and the regulations thereunder.” Sec.

Mulberry Motor Parts, Inc., Petitioner 114 T.C. No. 2 · 2000

he subject years. We see no judicial or equitable reason why Mr. Read will be precluded from arguing in the future that the payments which he receives on the promissory note in other years (with the exception 2 We note that the installment method of sec. 453 does not apply to the receipt of a distribution taxed as a dividend under sec. 301. The installment method may be used only to report “income” from a “disposition of property”, sec. 453(a) and (b)(1), and a “distribution of property” under s

Christa Karin Mueller, Petitioner T.C. Memo. 2001-178 · 2001

ioner is arguing that WLJ & Co., rather than JGC, should be considered the purchaser of the 38,860,956 MagnaCard shares from omni. In neither event, however, did husband's receipt of the demand debentures br.ing into play installment reporting under section 453. Section 453(a) provides that, generally, income from an installment sale shall be taken into account under the installment method of accounting. In pertinent part, section 453(b)(1) defines an installment sale as "a disposition of proper

Otrabanda Investerings Partnership; Brunswick Corporation, Tax Matters Partner, Petitioners T.C. Memo. 1999-359 · 1999

ately prior to the close of the partnerships' first taxable year, S and O sold their PPNs and CDs for cash (80 percent) and LIBOR notes (20 percent). These transactions were intended to satisfy the requirements of a contingent installment sale under I.R.C. sec. 453. Relying on the ratable basis recovery rules under sec. 15A.453-1(c), Temporary - 2 - Income Tax Regs., 46 Fed. Reg. 10711 (Feb. 4, 1981), the partnerships applied one-sixth of their bases in the PPNs and CDs in computing their "gains

Saba Partnership; Brunswick Corporation, Tax Matters Partner, Petitioners T.C. Memo. 1999-359 · 1999

ACM Partnership; Southampton-Hamilton Company, Tax Matters Partner, Petitioners T.C. Memo. 1997-115 · 1997

The Contingent Installment Sale Transaction ACM is one of 11 partnerships (section 453 partnerships) formed over a 1-year period from 1989 to 1990 by the Swap Group at Merrill Lynch & Co., Inc.1 Each section 453 partnership was intended to be a vehicle for sheltering capital gains of one of its partners.

Micka M. Oliver, Petitioner T.C. Memo. 2011-43 · 2011

The seller must report income received from an installment sale under the installment method unless she affirmatively elects not to do so." Sec. 453(a), (d) (1). Petitioner sold the real estate for $65,000, ·receiving earnest money of $2,500 and a promissory note in the amount of $62,500, executed by the buyers, which provided tha

TG Missouri Corp. v. Commissioner 133 T.C. 278 · 2009

The current section 453 titled “Installment Method” takes an approach similar to that of section 1239.

Estate of Barry E. Moore, Deceased; Randall Moore, Executor; and Deborah E. Moore, Petitioners T.C. Memo. 2007-134 · 2007

Moore’s gain on the sale of her membership interest in the LLC under the installment method, in accordance with section 453 (the installment method reporting issue).3 The notice contains certain other adjustments that are purely computational.

Walter L. Medlin, Petitioner T.C. Memo. 2003-224 · 2003

Under section 453B(a), gain or loss shall be recognized on the sale or exchange of an installment obligation to the extent of the difference between the basis of the obligation and the amount realized. The basis of an installment obligation shall be 14Respondent computed the installment gain in 1985 as follows: Gross profit ($59,272) = sales price ($69,0

Bud Raymond, Petitioner T.C. Memo. 2001-96 · 2001

As to (continued...) - 2 - by petitioner on account of receiving various promissory notes, (2) whether petitioner is entitled to use the installment method under section 453 to report gain realized from the sale of single family homes, and, if so, (3) whether petitioner properly reported his income according to that method.2 FINDINGS OF FACT Some of the facts have been stipulated and are so found.

Edward C. Tietig, Petitioner T.C. Memo. 2001-190 · 2001

was dated December 31, 1990. Therefore, the sale was made in 1990, and Farm & Grove must recognize income from the sale in 1990.20 Petitioner’s second timing argument is that the sale should be recognized under the installment method provided under section 453. For Federal income tax purposes, gain from qualifying installment sales of property can be reported under the installment method subject to certain exceptions. Sec. 453(a)(1). Dealer dispositions are excepted from the definition of “inst

Paul D. & Joyce E. Krause, Petitioner T.C. Memo. 2000-343 · 2000

The sole issue for decision is whether petitioners are entitled to report gain realized from the sale of real estate under the installment method pursuant to section 453 when petitioners, on their 1994 income tax return, reported the gain in full as a completed sale.

Claude M. & Mary B. Ballard, Petitioner · 1999

Whether Kanter, in 1983, Realized Capital Gains Under Section 357(b) and (c) From the Assumption by Cashmere Investment Associates, Inc., of Partnership Interests Having Negative Capital Accounts and Whether, Under Section 453, the Installment Method was Available for the Reporting of Such Gains .

Claude M. & Mary B. Ballard, Petitioner · 1999

Investment Research Associates Ltd., and Subsidiaries, Petitioner · 1999

Investment Research Associates, Ltd. and Subsidiaries, Petitioner · 1999

Estate of Robert W. Lisle, Deceased, Thomas W. Lisle & Amy L. Albrecht, Independent Co-Executors; and Estate of Donna M. Lisle, Deceased, Thomas W. Lisle & Amy L. Albrecht, Independent Co-Executors, Petitioners · 1999

Investment Research Associates, Ltd. and Subsidiaries, Petitioner · 1999

Estate of Burton W. Kanter, Deceased; Joshua S. Kanter, Executor; and Estate of Naomi R. Kanter, Deceased; Joshua S. Kanter, Executor, Petitioners · 1999

Investment Research Associates, Ltd. and Subsidiaries, Petitioner · 1999

Claude M. & Mary B. Ballard, Petitioner · 1999

Estate of Robert W. Lisle, Deceased; Thomas W. Lisle, and Amy L. Albrecht, Independent Co-Executors, and Estate of Donna M. Lisle, Deceased, Thomas W. Lisle and Amy L. Albrecht, Independent Co-Executors, Petitioners · 1999

Investment Research Associates, Ltd. and Subsidiaries, Petitioner · 1999

Estate of Burton W. Kanter, Deceased; Joshua S. Kanter, Executor; and Estate of Naomi R. Kanter, Deceased; Joshua S. Kanter, Executor, Petitioners · 1999

Investment Research Associates, Ltd. and Subsidiaries, Petitioner · 1999

Claude M. & Mary B. Ballard, Petitioner · 1999

Estate of Robert W. Lisle, Deceased; Thomas W. Lisle & Amy L. Albrecht, Independent Co-Executors, & Estate of Donna M. Lisle, Deceased, Thomas W. Lisle& Amy L. Albrecht, Independent Co-Executors, Petitioners · 1999

Estate of Burton W. Kanter, Deceased; Joshua S. Kanter, Executor; and Estate of Naomi R. Kanter, Deceased; Joshua S. Kanter, Executor, Petitioners · 1999

Burton W. Kanter & Naomi R. Kanter, Petitioners · 1999

Investment Research Associates, Ltd. and Subsidiaries, Petitioner · 1999

Burton W. Kanter & Naomi R. Kanter, Petitioners · 1999

Estate of Burton W. Kanter, Deceased; Joshua S. Kanter, Executor; and Estate of Naomi R. Kanter, Deceased; Joshua S. Kanter, Executor, Petitioners · 1999

Claude M. & Mary B. Ballard, Petitioner · 1999

Leslie S. Hirahara, Petitioner T.C. Memo. 1997-16 · 1997

Section 453 provides that income from an installment sale is accounted for under the installment method. Bolton v. Commissioner, 92 T.C. 303, 305 (1989). An installment sale is - 15 - defined as a disposition of property where at least one payment is to be received after the close of the taxable year in which the disposition occurs. Sec. 453(b)(1)

Don & Susanne C. Ballantyne, Petitioner T.C. Memo. 1996-456 · 1996

The cancellation requires recognition of gain of $4,121,930 under section 453B(a) .and (f) in 1986.5 Sec.

Patricia S. Makalintal, Petitioner T.C. Memo. 1996-9 · 1996

OPINION 1986 Income from Sale of ICPI Stock and Respondent’s Bank Deposit Analyses Section 453 provides generally that income from an installment sale shall be taken into account under the 1 The parties have stipulated that the $31,335 home mortgage interest expense deduction claimed on Mr.

Patricia S. Makalintal, Petitioner T.C. Memo. 1996-9 · 1996

Indu Rawat, Petitioner T.C. Memo. 2023-14 · 2023

Rawat under section 453A(c)(2)(B) as interest on the deferred tax liability attributable to the installment obligation (i.e., Mr.

Glenn David Cuthbertson a.k.a. David Cuthbertson and Pamela Cuthbertson, Petitioners · 2020

me tax purposes, to another LLC that was wholly owned by P-H, via direct and indirect ownership, and that was also treated as a non-TEFRA partnership for income tax purposes. Ps caused the seller LLC to use the installment method ofaccounting, under I.R.C. sec. 453, so as to defer the recognition ofgain on these transfers. SERVED Jan 14 2020 - 2 - [*2] These losses flowed through to Ps, and Ps claimed deductions for these losses on their 2009 and 2010 Forms 1040. In 2009 Ps also filed a Form 104

Larry E. Austin & Belinda Austin, Petitioners · 2017

It elected out ofinstallment sale treatment under section 453 and allocated 100% ofthe gain to the ESOP, allegedly the sole holder ofits then-outstanding shares, on a Schedule K-1, Shareholder's Share ofIncome, Deductions, Credits, etc.

Stanley Battat & Zmira Battat, Petitioners · 2017

2°Equitable recoupment is ajudicially created doctrine that in certain circumstances allows a litigant to avoid the bar ofan expired statutory limitations period. Bull v. United States, 295 U.S. 247 (1935). In the tax context the doctrine prevents the inconsistent tax treatment ofa single transaction, item, or event affecting the s

Estate of Arthur E. Kechijian, Deceased, Susan P. Kechijian and Scott E. Hoehn, Co-Executors, and Susan P. Kechijian, Petitioners · 2017

Gerd Topsnik, Petitioner · 2016

Section 453B(b) provides that a taxpayer's basis in an installment obligation is the excess ofthe face value ofthe obligation (the remaining principal amount) over an amount equal to the income which would be returnable were the obligation satisfied in full (the portion ofthe payments which would be included in the taxpayer's i

Pizza Pro Equipment Leasing, Inc., Petitioner · 2016

(CCH) 467, 472 ("The Commissioner has been given rather broad rulemaking authorityby section 453 and it would seem that ifhe considered it to be a reasonable and valid requirement under the statute that an affirmative election to use the installment method be made in an original and timely filed return for the year ofsale, he would so provide in his regulation.").

SI Boo, LLC, Boo Noz Corporation, Tax Matters Partner, Petitioners · 2015

Installment Sales Method ofAccounting Petitioners argue that under section 453 the entities are entitled to use the installment sales method to account for their sales ofproperties by contract for deed.24 Respondent disagrees, contending that the entities are precluded under 24Petitioners also argue on briefthat the Court should consider the entities' reliance on a purported settlement between S.

Sabre Group, LLC, Barrett Rochman Revocable Trust, Barrett Rochman, Trustee, Tax Matters Partner, Petitioners · 2015

S. I. Securities, LLC, Barrett Rochman Revocable Trust, Barrett Rochman, Trustee, Tax Matters Partner, Petitioners · 2015

Marvin E. DeBough, Petitioner · 2014

s. Sec. 121(b)(3). Congress added section 1038 to the Code by the Act ofSeptember 2, 1964, Pub. L. No. 88-570, sec. 2, 78 Stat. at 854. Before the enactment ofsection 1038, - 8 - reacquisition ofreal property was treated as a taxable exchange under section 453. S. Rept. No. 88-1361, at 5 (1964), 1964-2 C.B. 828, 831. If, as in this case, the initial sale ofthe propertywas reported as an installment sale, gain or loss on reacquisition ofthe property was treated as the difference between the fair

Charles T. Bruce & Mary A. Bruce, Petitioners · 2014

We therefore do not consider the applicability ofthe installment method to this sale. We also do not consider whetherthe fair market value ofthe notes was less than their face value. Petitioners have treated the values as the same, and we do likewise. - 47 - [*47] Seee Gregory v. Helvering, 293 U.S. at 469; Sandvall v. Commissioner, 898

DeBough v. Commissioner 142 T.C. 297 · 2014

years. Sec. 121(b)(3). Congress added section 1038 to the Code by the Act of September 2, 1964, Pub. L. No. 88-570, sec. 2, 78 Stat. at 854. Before the enactment of section 1038, reacquisition of real property was treated as a taxable exchange under section 453. S. Rept. No. 88-1361, at 5 (1964), 1964-2 C.B. 828, 831. If, as in this case, the initial sale of the property was reported as an installment sale, gain or loss on reacquisition of the property was treated as the difference between the f

Lori M. & John M. Mingo, Petitioner T.C. Memo. 2013-149 · 2013

ner, 22 T.C. 321 (1954), a taxpayer was given several options to purchase stock as compensation for his services. He sold these options rather than exercising them and attempted to report his gain under section 44(b), I.R.C. 1939, the predecessor to section 453. The Court held that the installment sale provisions did not apply to the sale because "[t]he provisions of section 44 relate only to the reporting ofincome arising from the sale ofproperty on the installment basis. Those provisions do no

Beyazit, LLC, RP Capital Partners, LLC, A Partner Other Than the Tax Matters Partner, Petitioners T.C. Memo. 2013-253 · 2013

3(c), Income Tax Regs. The taxpayermay rebut the presumption by carrying his or her burden to show facts and circumstances that "clearly establish "We fully expect the parties to apply during Rule 155 computations the rules ofinstallment sales under sec. 453 and time value ofmoney under sec. 1274 as is the case in the example in the regulations. -57- [*57] that the transfers do not constitute a sale." Id. (emphasis added); see Superior Trading, LLC v. Commissioner, T.C. Memo. 2012-110, 103 T.C.M

Buyuk LLC, Boyalik LLC, A Partner Other Than the Tax Matters Partner, Petitioners T.C. Memo. 2013-253 · 2013

Roger A. & Colleen C. Burton, Petitioner T.C. Memo. 2009-60 · 2009

Respondent' s revenue agent also proposed two altern tive adjustments (first alternative--recognize the ESOP but tr at the sale by the ESOP of the S corporation's assets as a°sale t at did not qualify under section 453 for installment sale repor ing ; second alternative-- recognize the ESOP but, if the sale of the .S corporation assets was treated as qualifying under sectio 453 for installment sale a -4- reporting, treat the sale of the assets under section 453(e) as a second disposition by a re

Richard E. & Mary Ann Hurst, Petitioner 124 T.C. No. 2 · 2005

From a tax perspective, a stock sale would give rise to long-term capital gain, taxed at lower rates than dividends.3 And by taking a 15-year note, rather than a lump sum, they could qualify for installment treatment under section 453, probably letting them enjoy a lower effective tax rate.

Shannon D. Mullins, Petitioner · 2005

or loss. See sec. 1221. A taxpayer must generally recognize the entire amount of the realized gain or loss. Sec. 1001(c). However, where there was an “installment sale”, a taxpayer can use the installment method to defer recognition of income.4 See sec. 453. An installment sale is a “disposition of property where at least 1 payment is to be received after the close of the taxable year in which the disposition occurs”. Sec. 453(b)(1). Under the installment method, a taxpayer recognizes a proporti

Hurst v. Commissioner 124 T.C. 16 · 2005

And by taking a 15-year note, rather than a lump sum, they could qualify for installment treatment under section 453, probably letting them enjoy a lower effective tax rate.

Otrabanda Investerings Partnership; Brunswick Corporation, Tax Matters Partner, Petitioners T.C. Memo. 2003-31 · 2003

siness units. In 1990, B joined with a foreign bank (ABN) purportedly to form two general partnerships, S and O. The partnerships engaged in financial transactions that were intended to satisfy the requirements of a contingent installment sale under I.R.C. sec. 453. Relying on the ratable basis recovery rules under sec. 15A.453-1(c), Temporary Income Tax Regs., 46 Fed. Reg. *This opinion supplements our previously filed Memorandum Opinion in Saba Pship. v. Commissioner, T.C. Memo. 1999-359, vaca

Saba Partnership; Brunswick Corporation, Tax Matters Partner, Petitioners T.C. Memo. 2003-31 · 2003

James W. & Laura L. Keith, Petitioner 115 T.C. No. 42 · 2000

The primary exception for income deferral is section 453, which provides for the “installment method” to be used in reporting an “installment sale”.

Keith v. Commissioner 115 T.C. 605 · 2000

The primary exception for income deferral is section 453, which provides for the “installment method’* to be used in reporting an “installment sale”.

Johannes M. Schalekamp, Petitioner T.C. Memo. 1998-277 · 1998

Section 453B deals specifically with gain or loss on the sale or other disposition of an installment obligation. The parties are in agreement that petitioner’s adjusted bases in the 1987 Ampel notes and the Holland Spring notes were $6,940,865 and $2,724,451, respectively. Their disagreement is with respect to the amount realized on each sale. The

Sooren Hovhannissian and Estate of Mary Hovhannissian, Deceased; Sooren Hovhannissian, Executor, Petitioners T.C. Memo. 1997-444 · 1997

nection with the reacquisition itself. Section 1038(b) requires only that the seller recognize and report as gain that amount of any cash or other property that was received by the seller on the original sale and whose recognition was deferred under section 453. Such recognition rectifies the imbalance created by the section 453 deferral, which Congress allowed in order to sidestep “the seemingly elementary issue of when the ‘amount realized’ by the seller includes the value of the buyer’s oblig

Sainte Claire Corporation; James F. Boccardo, Tax Matters Person, Petitioners T.C. Memo. 1997-171 · 1997

Claire disposed of the note, which was an installment obligation, within the meaning of section 453B.3 2 Although Sainte Claire elected to be an S corporation for its 1987 and 1988 taxable years, respondent determined that it was liable for tax on its excess net passive income pursuant to sec.

David & Naomi Dobrich, Petitioner T.C. Memo. 1997-477 · 1997

nd their gain realized is $3,687,175 ($3,969,000-$281,825). Installment Method Petitioners argue that they are entitled to report any gain that they must recognize from the sale of the Antioch property in - 19 - 1990 under the installment method of section 453. Section 453 permits taxpayers to report gain from the sale of property in the year payment is received. Payment includes amounts either actually or constructively received by the taxpayer. Sec. 15A.453-1(b)(3)(i), Temporary Income Tax Reg

David & Naomi Dobrich, Petitioner T.C. Memo. 1997-477 · 1997

Sainte Claire Corporation, Petitioner T.C. Memo. 1997-171 · 1997

Estate of Jewell E. Gray, Deceased; Jewell Mae Detjen, Personal Representative, Petitioners T.C. Memo. 1997-67 · 1997

453B(a); Krist v. Commissioner, 231 F.2d 548, 550 (9th Cir. 1956); Affiliated Capital Corp. v. Commissioner, 88 T.C. 1157, 1171 (1987). We conclude that the value of the stock of Beth W. Corp. should not be discounted for built-in tax liability on a capital gain. 9(...continued) (1977) (decedent owned an installment obligation which we did not

John T. Barrett, Jr. & Jane W. A. Barrett, Petitioners T.C. Memo. 1996-199 · 1996

The issues we must decide in the instant case are: (1) Whether petitioners, for taxable year 1989, must recognize a capital gain pursuant to the installment sale provisions of section 453 on petitioner John T.

Orville E. & Helen V. Christensen, Petitioner T.C. Memo. 1996-254 · 1996

es does not qualify for tax-free exchange treatment under section 1031, but is rather a sale and exchange of properties on which gain or loss is to be recognized, such transactions constitute sales that are reportable on the installment method under section 453. Petitioners, husband and wife, filed joint income tax returns for the years 1988 and 1989, and at the time of filing their petition herein were residents of California. In 1981, petitioner husband purchased a business property located in

Estate of Howard Berger, Deceased; Susan Berger, Administratrix, Petitioners T.C. Memo. 1996-76 · 1996

Respondent asserts that the sale on November 17, 1989, of Woodbine was a dealer disposition and therefore does not qualify as an installment sale under section 453.19 The installment method is not available for dispositions of personal property of a kind required to be included in the inventory of the taxpayer on hand at the close of the taxable year.

Estate of Howard Berger, Deceased; Susan Berger, Administratrix; and Susan Berger, Petitioners T.C. Memo. 1996-76 · 1996

Estate of Frane v. Commissioner 98 T.C. 341 · 1992

Read v. Commissioner 114 T.C. 14 · 2000

Shelton v. Commissioner 105 T.C. 114 · 1995

Estate of Silverman v. Commissioner 98 T.C. 54 · 1992

Tecumseh Corrugated Box Co. v. Commissioner 94 T.C. 360 · 1990

Applegate v. Commissioner 94 T.C. 696 · 1990

Nestlé Holdings, Inc. v. Commissioner 94 T.C. 803 · 1990

Chase v. Commissioner 92 T.C. 874 · 1989

Kerry v. Commissioner 89 T.C. 327 · 1987

Sallies v. Commissioner 83 T.C. 44 · 1984

Harold & Julia Gershman Family Foundation v. Commissioner 83 T.C. 217 · 1984

Hunt v. Commissioner 80 T.C. 1126 · 1983

Vaughn v. Commissioner 81 T.C. 893 · 1983

Cox v. Commissioner 78 T.C. 1021 · 1982

Estate of Skaggs v. Commissioner 75 T.C. 191 · 1980

Estate of Kearns v. Commissioner 73 T.C. 1223 · 1980

Porterfield v. Commissioner 73 T.C. 91 · 1979

Weaver v. Commissioner 71 T.C. 443 · 1978

Stiles v. Commissioner 69 T.C. 558 · 1978

Maddox v. Commissioner 69 T.C. 854 · 1978

Bostedt v. Commissioner 70 T.C. 487 · 1978

212 Corp. v. Commissioner 70 T.C. 788 · 1978

Sirbo Holdings, Inc. v. Commissioner 61 T.C. 723 · 1974

Smith v. Commissioner 56 T.C. 263 · 1971

Oden v. Commissioner 56 T.C. 569 · 1971

National Western Life Insurance v. Commissioner 54 T.C. 33 · 1970

Holmes v. Commissioner 55 T.C. 53 · 1970

Robinson v. Commissioner 54 T.C. 772 · 1970

Horneff v. Commissioner 50 T.C. 63 · 1968

Rothenberg v. Commissioner 48 T.C. 369 · 1967

Family Record Plan, Inc. v. Commissioner 36 T.C. 305 · 1961

American Offshore, Inc. v. Commissioner 97 T.C. 579 · 1991

Wrenn v. Commissioner 67 T.C. 576 · 1976

Realty Loan Corp. v. Commissioner 54 T.C. 1083 · 1970

Town & Country Food Co. v. Commissioner 51 T.C. 1049 · 1969

10-42 Corp. v. Commissioner 55 T.C. 593 · 1971

Mitchell v. Commissioner 42 T.C. 953 · 1964

Monaghan v. Commissioner 40 T.C. 680 · 1963

Carlson v. Commissioner 112 T.C. 240 · 1999

Bolton v. Commissioner 92 T.C. 303 · 1989

Juda v. Commissioner 90 T.C. 1263 · 1988

Professional Equities, Inc. v. Commissioner 89 T.C. 165 · 1987

Marcor, Inc. v. Commissioner 89 T.C. 181 · 1987

Joe Kelly Butler, Inc. v. Commissioner 87 T.C. 734 · 1986

Wierschem v. Commissioner 82 T.C. 718 · 1984

Mariani Frozen Foods, Inc. v. Commissioner 81 T.C. 448 · 1983

Click v. Commissioner 78 T.C. 225 · 1982

Arnwine v. Commissioner 76 T.C. 532 · 1981

King v. Commissioner 77 T.C. 1113 · 1981

Greene v. Commissioner 76 T.C. 1018 · 1981

Griffith v. Commissioner 73 T.C. 933 · 1980

Ernestine M. Carmichael Trust No. 21-35 v. Commissioner 73 T.C. 118 · 1979

Lustgarten v. Commissioner 71 T.C. 303 · 1978

Roberts v. Commissioner 71 T.C. 311 · 1978

Warren Jones Co. v. Commissioner 68 T.C. 837 · 1977

Weyher v. Commissioner 66 T.C. 825 · 1976

Frizzelle Farms, Inc. v. Commissioner 61 T.C. 737 · 1974

W. T. Grant Co. v. Commissioner 58 T.C. 290 · 1972

Farha v. Commissioner 58 T.C. 526 · 1972

Kirschenmann v. Commissioner 57 T.C. 524 · 1972

Harper v. Commissioner 54 T.C. 1121 · 1970

Swaim v. Commissioner 50 T.C. 302 · 1968

Swaim v. Commissioner 50 T.C. 336 · 1968

Wilkinson v. Commissioner 49 T.C. 4 · 1967

Merritt v. Commissioner 47 T.C. 519 · 1967

Irwin v. Commissioner 45 T.C. 544 · 1966

Walker v. Commissioner 46 T.C. 630 · 1966

Reaver v. Commissioner 42 T.C. 72 · 1964

United Pacific Corp. v. Commissioner 39 T.C. 721 · 1963

Denco Lumber Co. v. Commissioner 39 T.C. 8 · 1962

Ludlow v. Commissioner 36 T.C. 102 · 1961

John F. v. Commissioner 35 T.C. 288 · 1960

Grandview Mines v. Commissioner 32 T.C. 759 · 1959

Estate Burton Kanter v. CIR · Cir.

James L. Thom Jean M. Thom v. United States of America, Leroy W. Thom Jean E. Thom v. United States of America, David W. Thom Janis Thom v. United States of America, Tom Thom Ladena Thom v. United States 283 F.3d 939 · Cir.

John & Janet Aldeborgh, Petitioner T.C. Memo. 2012-8 · 2012

Vecchio v. Commissioner 103 T.C. 170 · 1994

First Chicago Corp. v. Commissioner 96 T.C. 421 · 1991

Southern California Savings & Loan Ass'n v. Commissioner 95 T.C. 35 · 1990

Gunther v. Commissioner 92 T.C. 39 · 1989

Conners v. Commissioner 88 T.C. 541 · 1987

Porter v. Commissioner 88 T.C. 548 · 1987

Gibson v. Commissioner 89 T.C. 1177 · 1987

Foy v. Commissioner 84 T.C. 50 · 1985

New Mexico Timber Co. v. Commissioner 84 T.C. 1290 · 1985

Packard v. Commissioner 85 T.C. 397 · 1985

Magneson v. Commissioner 81 T.C. 767 · 1983

Bowen v. Commissioner 78 T.C. 55 · 1982

Monson v. Commissioner 79 T.C. 827 · 1982

Roy H. Park Broadcasting, Inc. v. Commissioner 78 T.C. 1093 · 1982

Ledoux v. Commissioner 77 T.C. 293 · 1981

Stern v. Commissioner 77 T.C. 614 · 1981

Goodman v. Commissioner 74 T.C. 684 · 1980

Hynes v. Commissioner 74 T.C. 1266 · 1980

Lake Gerar Development Co. v. Commissioner 71 T.C. 887 · 1979

Estate of Brock v. Commissioner 71 T.C. 901 · 1979

McShain v. Commissioner 71 T.C. 998 · 1979

Estate of Wiggins v. Commissioner 72 T.C. 701 · 1979

Biggs v. Commissioner 69 T.C. 905 · 1978

Pityo v. Commissioner 70 T.C. 225 · 1978

Voight v. Commissioner 68 T.C. 99 · 1977

McShain v. Commissioner 68 T.C. 154 · 1977

Holcomb v. Commissioner 68 T.C. 786 · 1977

Estate of Robinson v. Commissioner 69 T.C. 222 · 1977

Schniers v. Commissioner 69 T.C. 511 · 1977

Doggett v. Commissioner 66 T.C. 101 · 1976

McShain v. Commissioner 65 T.C. 686 · 1976

Snyder v. Commissioner 66 T.C. 785 · 1976

Cox v. Commissioner 62 T.C. 247 · 1974

Hosking v. Commissioner 62 T.C. 635 · 1974

Pritchett v. Commissioner 63 T.C. 149 · 1974

Westchester Development Co. v. Commissioner 63 T.C. 198 · 1974

Columbia Iron & Metal Co. v. Commissioner 61 T.C. 5 · 1973

Warren Jones Co. v. Commissioner 60 T.C. 663 · 1973

W. S. Badcock Corp. v. Commissioner 59 T.C. 272 · 1972

Sirbo Holdings, Inc. v. Commissioner 57 T.C. 530 · 1972

Mathers v. Commissioner 57 T.C. 666 · 1972

Estate of Gerard v. Commissioners 57 T.C. 749 · 1972

Estate of Shea v. Commissioner 57 T.C. 15 · 1971

Vest v. Commissioner 57 T.C. 128 · 1971

Legg v. Commissioner 57 T.C. 164 · 1971

Hicks Co. v. Commissioner 56 T.C. 982 · 1971

Harris v. Commissioner 56 T.C. 1165 · 1971

Luckman v. Commissioner 56 T.C. 1216 · 1971

Lockhart Leasing Co. v. Commissioner 54 T.C. 301 · 1970

Rickey v. Commissioner 54 T.C. 680 · 1970

Rose v. Commissioner 55 T.C. 28 · 1970

Pomeroy v. Commissioner 54 T.C. 1716 · 1970

Waldrep v. Commissioner 52 T.C. 640 · 1969

Rushing v. Commissioner 52 T.C. 888 · 1969

Schuster v. Commissioner 50 T.C. 98 · 1968

Branham v. Commissioner 51 T.C. 175 · 1968

Coast Coil Co. v. Commissioner 50 T.C. 528 · 1968

Pozzi v. Commissioner 49 T.C. 119 · 1967

Clodfelter v. Commissioner 48 T.C. 694 · 1967

Knollwood Memorial Gardens v. Commissioner 46 T.C. 764 · 1966

Apollo Industries, Inc. v. Commissioner 44 T.C. 1 · 1965

Cunningham v. Commissioner 44 T.C. 103 · 1965

Potter v. Commissioner 44 T.C. 159 · 1965

Marcello v. Commissioner 43 T.C. 168 · 1964

Gunderson Bros. Engineering Corp. v. Commissioner 42 T.C. 419 · 1964

Luhring Motor Co. v. Commissioner 42 T.C. 732 · 1964

F. E. McGillick Co. v. Commissioner 42 T.C. 1059 · 1964

Blueberry Land Co. v. Commissioner 42 T.C. 1137 · 1964

Mamula v. Commissioner 41 T.C. 572 · 1964

First Savings & Loan Ass'n v. Commissioner 40 T.C. 474 · 1963

Stanley v. Commissioner 40 T.C. 851 · 1963

Spivey v. Commissioner 40 T.C. 1051 · 1963

Jack Ammann Photogrammetric Engineers, Inc. v. Commissioner 39 T.C. 500 · 1962

Freeman v. Commissioner 36 T.C. 779 · 1961

Ireland v. Commissioner 32 T.C. 994 · 1959

Frankenstein v. Commissioner 31 T.C. 431 · 1958

Tank Truck Rentals, Inc. v. Commissioner 26 T.C. 427 · 1956

Gilbert v. Commissioner 25 T.C. 81 · 1955

Estate of Showers v. Commissioner 14 T.C. 902 · 1950

Mills v. Commissioner 12 T.C. 468 · 1949

Taurog v. Commissioner 11 T.C. 1016 · 1948

Bryan v. Commissioner 9 T.C. 611 · 1947

Francis v. Commissioner 8 T.C. 822 · 1947

United States v. Conces 507 F.3d 1028 · Cir.

Mingo v. Commissioner 773 F.3d 629 · Cir.

United States v. Conces · Cir.

Jean A. Stanko v. CIR · Cir.

James L. Thom v. United States 283 F.3d 939 · Cir.

Keith Scherbart v. CIR · Cir.

Mark J. Wittman v. Timothy A. Koenig · Cir.

Hooker v. Federal Election Commission 21 F. App'x 402 · Cir.

Jean A. Stanko v. Commissioner of Internal Revenue 209 F.3d 1082 · Cir.

Keith Scherbart Janet Scherbart v. Commissioner of Internal Revenue 453 F.3d 987 · Cir.

Wittman v. Koenig 831 F.3d 416 · Cir.

§453 — Installment method

261 Citing Cases

New cases, delivered.