Terry Duane Beall and Joyce Engel Beall - Page 2

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          The issues for decision are (1) whether petitioners are entitled            
          to roll over the gain on the sale of their residence under                  
          section 1034, and (2) whether petitioners are liable for the                
          accuracy-related penalty for negligence.                                    
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and attached exhibits are incorporated             
          herein by this reference.  Petitioners resided in Coronado,                 
          California, when the petition was filed.                                    
               Petitioners Terry Duane Beall (Terry) and Joyce Engel Beall            
          (Joyce) are husband and wife.  They were married in 1954.  In               
          1959, petitioners moved to Riverside, California.  They had two             
          children:  Marc, born in November 1955, and Julie, born in July             
          1957.  Both children attended high school in Riverside.  As of              
          1980, neither child lived at home with petitioners.                         
               Since 1955, Terry has worked in the insurance business.                
          From 1959 to 1964, he worked at Beall, Hughes & Associates, in              
          Riverside, which specialized in selling life insurance to                   

          in effect for the year in issue, and all Rule references are to             
          the Tax Court Rules of Practice and Procedure, unless otherwise             

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Last modified: May 25, 2011