Paul L. Blanton and Cynthia D. Blue-Blanton - Page 2

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               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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