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various dates in the year 1989. Accordingly, we agree with
petitioner and respondent and hold that although the Tesconi
property was conveyed by petitioner husband to the purchasers in
1988, no payment therefor was received until 1989, so that an
installment sale took place under section 453(b). Since
respondent did not determine that any taxable sale took place in
the year 1989, nor any deficiency of tax resulting therefrom, we
need to make no further determinations regarding this matter, but
simply hold that respondent's determination of additional income
for 1988 on account of the Tesconi transfer was in error.
Decision will be entered
under Rule 155.
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