- 2 - decision to be entered is not reviewable by any other court, and this opinion should not be cited as authority. Respondent determined deficiencies of $378, $896, and $9,570 in petitioner’s Federal income taxes for taxable years 1993, 1994, and 1995, respectively. In addition, respondent determined accuracy-related penalties under section 6662(a) of $76 and $1,914 for taxable years 1993 and 1995, respectively. The issues remaining for decision are: (1) Whether petitioner must recognize gain from the sale of his personal residence in taxable year 1993, and (2) whether petitioner is liable for accuracy-related penalties under section 6662(a) for taxable years 1993 and 1995.1 Background The stipulation of facts and the accompanying exhibits are incorporated herein by reference. Petitioner resided in Tigard, Oregon, at the time his petition was filed in this case. Petitioner has been a certified public accountant for 25 years. In March 1989, petitioner and his wife, Sandra K. Bare (now deceased), purchased a residential property located at 1461 N.E. Burns Street, West Linn, Oregon (the Burns Street property), for $80,100. 1 The parties reached agreement on the amount of gain to be recognized on the sale of petitioner’s business property, and respondent concedes the sec. 6662(a) accuracy-related penalty for taxable year 1995 insofar as it relates to that issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011