Richard Bruce Begelfer - Page 2

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            tax in the amount of $1,635 for substantial understatement of tax                           
            pursuant to section 6661.                                                                   
                  After a concession by respondent,2 the sole issue for our                             
            decision is whether petitioner is entitled to nonrecognition                                
            treatment under section 1034 for the gain he realized on the sale                           
            of his principal residence.                                                                 
                  Some of the facts have been stipulated and are so found.                              
            The stipulation of facts and attached exhibits are incorporated                             
            herein by this reference.  At the time the petition was filed,                              
            petitioner resided in Long Beach, New York.  Subsequently,                                  
            petitioner relocated to Texas in November 1992.                                             
                  During a part of 1987, petitioner resided in Bridgeport,                              
            Connecticut.  In February of that year, petitioner lost his job                             
            when his employer became insolvent and decided to discontinue                               
            operations.  Because of financial difficulties, petitioner sold                             
            his principal residence on May 1, 1987, and realized a capital                              
            gain of $36,171.  Petitioner did not report this gain on his 1987                           
            Federal income tax return.  Rather, petitioner chose to defer                               
            recognition of the gain because he intended to replace his home                             
            within the replacement period provided by section 1034.                                     
                  Petitioner moved to the New York City area, and in August                             
            1987 found full-time employment as a sales agent.  During this                              


            2  At trial, respondent conceded that petitioner was not liable                             
            for an addition to tax for substantial understatement of tax                                
            under sec. 6661 for the 1987 taxable year.                                                  




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