- 12 - consideration of the payment of a contract value amount). Petitioners have failed to introduce evidence of vendible assets or show language referencing a contract of sale. That is sufficient for us to conclude that petitioner received no payment for any property. See Schelble v. Commissioner, T.C. Memo. 1996- 269, affd. 130 F.3d 1388 (10th Cir. 1997). We reach the same conclusion that we reached in Farnsworth v. Commissioner, supra, also involving a district manager’s agreement, that neither in form nor in substance did the cancellation of the agreement give rise to the sale of property by petitioner. See also Clark v. Commissioner, supra. We sustain in full the deficiencies in tax determined by respondent. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011