Opinion
No. 72-2233.
May 15, 1974.
William C. Ruthford (argued), Jones, Grey, Bayley Olsen, Seattle, Wash., for petitioners-appellants.
David English Carmack (argued), Scott P. Crampton, Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Washington, D.C., Lee H. Henkel, Jr., Acting Chief Counsel, IRS, Washington, D.C., Richard J. Shipley, Seattle, Wash., for respondent-appellee.
Appeal from the Tax Court.
OPINION
The Tax Court, concluding that taxpayers' transfer of their vendors' interest in an installment contract to an irrevocable trust constituted a disposition within the purview of 26 U.S.C. § 453 (d) and thus subjected the gain to immediate recognition, affirmed the Commissioner's determination of deficiencies in their income tax. 57 T.C. 164.
A review of the record discloses that all factual determinations are supported by the evidence, that the relevant statutory provisions were properly construed and applied, and that the rationale of the Tax Court was correct and ought to be approved.
Affirmed.