Edgar L. and Joan H. Parker - Page 12




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          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.                          





















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