Donna M. Neighbors - Page 1

                                 T.C. Memo. 1998-263                                  

                               UNITED STATES TAX COURT                                

                          DONNA M. NEIGHBORS, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 27654-96.                    Filed July 20, 1998.           

               David W. Freese, for petitioner.                                       
               Lisa M. Oshiro, for respondent.                                        

                                 MEMORANDUM OPINION                                   

               LARO, Judge:  This case was submitted to the Court fully               
          stipulated.  See Rule 122.  Petitioner petitioned the Court to              
          redetermine respondent's determination of a $20,488 deficiency in           
          her 1991 Federal income tax and a $4,098 accuracy-related penalty           
          under section 6662(a).  We must decide whether petitioner                   
          realized a $92,388 gain on the sale of her personal residence               

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