- 7 - petitioners reported the gain from this sale under the installment method. Petitioners did not introduce into evidence a copy of their 1977 Federal income tax return. In 1979, the Reeds sold their interest in Arizona Marine to Mr. and Mrs. Lee Lieberman. Petitioners agreed to the release of the Reeds from their obligations, and the substitution of the Liebermans. The Liebermans executed a promissory note dated October 1, 1979, in the amount of $117,464.48, payable to petitioners. The Liebermans also granted petitioners a security interest in certain inventory and equipment of Arizona Marine. The record does not disclose how petitioners treated this transaction on their 1979 Federal income tax return. In 1980, the Liebermans defaulted under the promissory note and petitioners filed an action for injunction and forcible entry and detainer against Arizona Marine in the Superior Court of the State of Arizona, Maricopa County. At the time of default, the balance due on the promissory note was $112,334.25. The action was settled under the terms of a settlement agreement and an agreement relating to petitioners' lessor's lien and security interest in certain Arizona Marine property. The settlement agreement, entered into on May 9, 1980, provides: 3. [Arizona Marine] agrees to, contemporaneously with the surrender of the premises to Burns, also surrender to Burns the following: (a) All of its inventory which consists of goods, merchandise and other personal property owned by [Arizona Marine] in connection with itsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011