- 2 -
petitioner’s Federal income tax for taxable year 1994. The sole
issue for decision is whether petitioner is entitled to
nonrecognition of gain from the sale of her personal residence in
1994 pursuant to the provisions of section 1034.
The stipulation of facts and the accompanying exhibits are
incorporated herein by reference. Petitioner resided in
Vancouver, Washington, at the time her petition was filed in this
case.
In 1982 petitioner purchased a residence located at 2105 NE
95th Avenue, Vancouver, Washington (2105 house). In 1990
petitioner purchased a residence located at 17217 NW 61st Avenue,
Ridgefield, Washington (Ridgefield house). The 2105 house was
converted to rental property in 1990, and the Ridgefield house
was petitioner’s primary residence from 1990 through September
1994.
In September 1994 petitioner sold the Ridgefield house and
converted the 2105 house to her primary residence. Petitioner
reported the sale of the Ridgefield house on her 1994 Form 1040
PC, U.S. Individual Income Tax Return, and deferred the gain.
On March 26, 1996, petitioner purchased and occupied a
residence at 2106 NE 104th Avenue, Vancouver, Washington (2106
house). On March 27, 1996, petitioner sold the 2105 house.
On September 30, 1996, petitioner filed a Form 1040X,
Amended U.S. Individual Income Tax Return, for taxable year 1994,
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011