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effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in petitioner’s Federal
income taxes of $15,117 and $3,957 for the taxable years 1996 and
1997.
After concessions by petitioner,1 the sole issue for
decision is whether, and if so to what extent, petitioner is
required to include in income long-term capital gain of $49,297
realized from the sale of her personal residence in 1996.
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Lee’s Summit, Missouri, on the date the petition was filed in
this case.
In 1973, petitioner and her former husband, Clinton Anthony,
purchased a residence in Compton, California, for $29,900. They
made no major improvements to the residence. On January 17,
1984, petitioner was divorced from Mr. Anthony in California.
Pursuant to the agreement, by deed dated March 14, 1984, Mr.
1For taxable year 1996, petitioner concedes she is not
entitled to disallowed itemized deductions of $20,750, solely
contingent upon a possible computational adjustment to the
claimed medical expense deduction which may be required pursuant
to the Court’s holding on the remaining issue in this case. For
taxable year 1997, petitioner concedes the entire deficiency.
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