Bud Raymond - Page 2

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          by petitioner on account of receiving various promissory notes,             
          (2) whether petitioner is entitled to use the installment method            
          under section 453 to report gain realized from the sale of single           
          family homes, and, if so, (3) whether petitioner properly                   
          reported his income according to that method.2                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, stipulation of settled issues, and the            
          accompanying exhibits are incorporated herein by this reference.            
          At the time petitioner filed the petition, he resided in Atwater,           
               During 1995, petitioner operated as a sole proprietorship              
          under the name Bud G. Raymond Construction.  For three                      
          generations, the members of the Raymond family have been involved           
          in the construction business.  Petitioner and his father and son            
          have been home builders.  Petitioner became involved in the                 
          construction business when he helped his father build                       

          subsequent determinations, petitioner and respondent agree that             
          petitioner must report interest income of $42,072, rental income            
          of $18,849 on Schedule E, Supplemental Income and Loss, income of           
          $1,027 on Schedule F, Profit or Loss From Farming, other income             
          of $4,694, and Social Security benefits of $8,462.  Petitioner              
          and respondent also agree that computational adjustments may be             
          required for self-employment taxes and the deduction associated             
          with the self-employment taxes imposed.                                     
               2  All section references are to the Internal Revenue Code             
          in effect for the year in issue, and all Rule references are to             
          the Tax Court Rules of Practice and Procedure.                              

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