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