T.C. Memo. 1998-322
UNITED STATES TAX COURT
DOUGLASS H. AND SUZANNE M. BARTLEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14941-97. Filed September 10, 1998.
Douglass H. and Suzanne M. Bartley, pro sese.
Frederic J. Fernandez and Mark J. Miller, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Respondent determined a $12,952 deficiency in
petitioners' 1993 Federal income tax and a section 6662(a)
accuracy-related penalty. Following concessions by petitioners,
the issues for decision are (1) whether petitioners must include as
income the gain realized from the sale of their residence in 1993,
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