- 2 - Held: Each contract for deed effected a completed sale for tax purposes in the year of execution, and income attributable to such disposition must be recognized and reported for that taxable year. Held, further, the net operating loss carryovers claimed by Ps must be adjusted to take into account income which should have been reported in years preceding those at issue, for contracts entered during such prior periods. Held, further, Baertschi v. Commissioner, 49 T.C. 289 (1967), revd. 412 F.2d 494 (6th Cir. 1969), will no longer be followed. William J. White, for petitioners. Nancy E. Hooten and Mark S. Mesler, for respondent. OPINION NIMS, Judge: Respondent determined the following deficiencies and penalties with respect to petitioners’ Federal income taxes for the taxable years 1993, 1994, and 1995: Taxable Income Tax Penalty Year Deficiency Sec. 6662(a) 1993 $74,925.00 $14,985 1994 127,304.00 25,461 1995 106,261.54 21,252 After concessions, the issues remaining for decision are: (1) The proper method of accounting for, and timing of recognition of gain attributable to, sales of property by means of contracts for deed; andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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