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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.
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