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P.C., an S corporation. On Form 6252, Installment Sale
Income, petitioners reported that they had received
$617,482 from the sale of Mr. Harrison's interest in the
Houston firm, of which 94.77 percent or $585,188 was long-
term capital gain from an installment sale.
The following schedule deals with petitioners' returns
for the years 1986 through 1992. It shows the filing date
of each return, the total tax shown on each return, the
amount of tax, interest, and penalty paid with each return,
and the amount of tax paid on or before April 15th of the
following year:
Return Total Tax Amount Paid Amount Paid
Year Filed Per Return With Return Prior to 4/15
1986 10/16/87 $26,449 $26,801 $118
1987 10/15/88 117,799 119,585 -0-
1988 10/17/89 96,418 101,093 1,408
1989 10/16/90 38,702 41,915 2,374
1990 10/18/91 124,103 124,186 2,560
1991 10/19/92 113,316 107,966 5,350
1992 10/18/93 79,675 -0- -0-
Notice of Deficiency
Respondent issued a notice of deficiency to
petitioners with respect to their 1988, 1989, and 1990
returns. Among the other adjustments made in the notice,
respondent determined that the payment of $500,000
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