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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,
California.
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
1(...continued)
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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