Karen Y. Nielsen - Page 2

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                  Richard Hopewell, for petitioner.                                                    
                  Albert B. Kerkhove, for respondent.                                                  


                                               OPINION                                                 
                  NIMS, Judge:  Respondent determined a Federal income tax                             
            deficiency for petitioner’s 1992 taxable year in the amount of                             
            $7,022.  The sole issue for decision is whether proceeds received                          
            by petitioner from the condemnation of her residence are subject                           
            to taxation as capital gain to the extent that they exceeded her                           
            basis in the property.                                                                     
                  Unless otherwise indicated, all section references are to                            
            sections of the Internal Revenue Code in effect for the year in                            
            issue, and all Rule references are to the Tax Court Rules of                               
            Practice and Procedure.                                                                    
                  This case was submitted fully stipulated pursuant to Rule                            
            122.  The stipulations of the parties, with accompanying                                   
            exhibits, are incorporated herein by this reference.                                       
                                             Background                                                
                  Karen Y. Nielsen, formerly known as Karen Y. Mundt, resided                          
            in Sioux Falls, South Dakota, at the time of filing her petition                           
            in this case.  More than 1 year prior to 1989, petitioner had                              
            obtained title to a home located at 222 North Cliff Avenue in                              










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