Citation Codes Equivalent Citations citation codes Docket Number No. 72-2233. Attorney(S) 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. Judges Montgomery Oliver Koelsch John Clifford Wallace Acts Internal Revenue Code — Income Taxes — Normal Taxes And Surtaxes — Accounting Periods And Methods Of Accounting — Methods Of Accounting — Taxable Year For Which Items Of Gross Income Included — Installment Method See more information ... Smart Summary Please sign up to generate summary. A. W. AND WILLIAMENA LEGG, PETITIONERS-APPELLANTS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE. OPINION PER CURIAM: 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.