Taxpayer, the Warren Jones Company, entered into a real estate contract to sell an apartment building for $153,000 on May 27, 1968 to Bernard and Jo An Storey. On June 15, 1968, the sale closed and the Storeys paid taxpayer $20,000 in cash and took possession of the apartment building. The contract then required the Storeys to pay the taxpayer $1,000 per month, plus 8 percent interest on the declining balance, for the next fifteen years. The balance due at the end of period was to be payable in a lump sum. Deed would then pass to the Storeys from taxpayer.
