T.C. Memo. 1995-535
UNITED STATES TAX COURT
HENRY ALLEN WATERS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8798-93. Filed November 13, 1995.
Henry Allen Waters, pro se.
Lori M. Mersereau, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent, by notice of deficiency,
determined that petitioner is liable for a deficiency in his 1989
Federal income tax and an addition to tax in the amounts of
$38,405 and $7,681, respectively. The issues for decision are:
(1) Whether the gain realized by petitioner from the sale of his
principal residence qualifies for nonrecognition treatment under
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