- 5 - Petitioners' 1990 Federal individual income tax return included only 45 percent of the principal received on the long- term note. The gain was determined under the installment method. The return failed to include, as part of the computation of gain, the $23,000 cash received, the debt from which petitioner was relieved in the amount of $31,200, and the remaining 55 percent of the sales proceeds. Petitioners' 1991 return similarly included only 45 percent of the principal payments on the long- term note in the computation of gain under the installment method. Petitioners' returns for 1990 and 1991 each included only 45 percent of the interest income received on the long-term note. During 1990, petitioner paid Linda Friscone $17,798.02 from the proceeds he received on the sale of the MUI stock. During 1991, petitioner paid Linda Friscone $10,041.16 from the proceeds he received on the sale of the MUI stock. Section 61(a)(3) includes in gross income "all income from whatever source derived, including * * * Gains derived from dealings in property". Section 1001(a) defines the amount of gain from sale or other disposition of property as "the excess of the amount realized therefrom over the adjusted basis". The amount realized also includes "the amount of liabilities from which the transferor is discharged as a result of the sale or disposition." Sec. 1.1001-2(a)(1), Income Tax Regs. Section 1001(c) requires that "Except as otherwise provided in thisPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011