Theodore B. Bare - Page 3




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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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