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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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