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dispositions, however, are not installment sales; therefore, the
gains associated with those dispositions cannot be reported under
the installment method. See sec. 453(b)(2)(A).
The Parties’ Disagreements
Petitioner and respondent disagree over whether petitioner
may use the installment method to report income. Before we
evaluate whether petitioner is entitled to use the installment
method, we deal with petitioner’s assertion at trial that he
would have been “lucky” to receive 25 percent of the face value
of the promissory notes. Based on the evidence before us, we
have found that petitioner received 41 promissory notes (with a
total face value of $423,770) secured by second deeds of trust.
Petitioner has not introduced any evidence other than his self-
serving testimony indicating that the fair market value of the
notes was less than the face value. Because petitioner has
failed to do so, we conclude that the amount realized includes
the total face value of the promissory notes. See Estate of
Silverman v. Commissioner, 98 T.C. 54, 61-62 (1992); McShain v.
Commissioner, 71 T.C. 998, 1003-1005 (1979); see also Wood v.
Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C.
593 (1964); Tokarski v. Commissioner, 87 T.C. 74, 76-77 (1986).
Petitioner claims that pursuant to section 453, he is
entitled to defer the gain relating to the sale of the 41 homes
until the promissory notes are converted into cash. Respondent
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