Michele Anthony - Page 3

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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           
               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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