Mingo v. Comm'r of Internal Revenue, No. 13-60801 (5th Cir. 2014)
Annotate this CaseIn 2002, the Mingos, married taxpayers, reported the sale of a partnership interest, including the portion of the proceeds attributable to the partnership’s unrealized receivables, through the installment method of accounting. In an action brought to determine their federal income tax liability, the tax court held that the Mingos were not entitled to utilize the installment method to report the unrealized receivables and that the IRS appropriately applied section 481(a) of the Internal Revenue Code in 2007 to adjust the Mingos’s 2003 joint income tax return to account for the unrealized receivables income that should have been reported in 2002. The Fifth Circuit affirmed, rejecting a claim that the determination that the installment sale reporting of the unrealized receivables in 2002 did not clearly reflect Mrs. Mingo’s income and a challenge to the Commissioner’s authority to change her method of accounting in 2003, given that the allegedly erroneous reporting under the installment method occurred in 2002, the year of the sale.
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