-2-
1. Whether petitioners may exclude $125,000 of the gain
from the sale of their principal residence in 1992 under section
121. We hold that they may not.
2. Whether petitioners are liable for the addition to tax
under section 6651(a)(1) for failure to file timely their 1992
income tax return. We hold that they are.
Unless otherwise indicated, section references are to the
Internal Revenue Code. Rule references are to the Tax Court
Rules of Practice and Procedure.
FINDINGS OF FACT
A. Petitioners
Petitioners lived in Spokane, Washington, when they filed
the petition in this case.
Petitioner Paul L. Blanton (Mr. Blanton) was born on March
4, 1930, and was 62 years old on October 30, 1992. In 1989,
petitioners had one son, Terrence, who was 2 years old.
Mr. Blanton taught at the University of Idaho in Moscow,
Idaho, from 1957 until he retired in 1990. In 1989, he was the
dean of the College of Arts and Architecture. He stepped down as
dean in September 1989. He commuted from Spokane, Washington, to
teach one course at the University from September 1989 to
sometime in 1990.
In 1989 and 1990, Mrs. Blanton was an associate professor of
interior planning and design in the Department of Architecture at
the University of Idaho in Moscow.
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