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$149,793 and that his taxable gain on the sale of the Castro
Valley house was $8,451 ($158,244 adjusted sales price of the
Castro Valley house less the $149,793 cost of the condominium).
In the notice of deficiency dated February 3, 1995,
respondent determined that petitioner realized a capital gain of
$77,396 that must be recognized in 1990 on the sale of his Castro
Valley house.
The condominium in Incline Village, Nevada, is approximately
200 miles from the corporate office building in Oakland,
California. It took petitioner approximately 4 hours to drive
from the condominium to the office building. From the time
petitioner acquired the condominium until July 19932, he resided
in the condominium on weekends and during vacation periods.
During the work week, he stayed in the vicinity of his place of
work (the San Francisco Bay area). When petitioner was in the
San Francisco Bay area he usually stayed with his mother or
friends who live in the area, but occasionally he stayed in a
hotel.
Petitioner has received his personal mail at the office
building since he acquired the building in 1980. Although
petitioner was not registered to vote during 1988 through 1991,
he had a California driver's license, filed income tax returns
2In July 1993 petitioner sold the condominium and purchased
a house in Incline Village.
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