2 petitioner is liable for tax on one-half of the capital gain realized on the sale of a house (the Arden Road house) that his former wife owned, one-half of the sale proceeds of which were awarded to him when he and his wife were divorced. We hold that he is not liable for tax on any of the capital gain. Thus, petitioner is not liable for the accuracy-related penalty under section 6662 for substantial understatement of tax for 1994 relating to the gain on the sale of the Arden Road house.1 Section references are to the Internal Revenue Code in effect during the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure. Background The parties submitted this case fully stipulated under Rule 122. A. Petitioner Petitioner was born in 1942, and he lived in Thornville, Ohio, when he filed his petition. Petitioner is an attorney and has practiced law since 1970. B. Petitioner’s Marriage to Mary Lois Suhr Petitioner and Mary Lois Suhr (Mrs. Suhr) were married in 1964 in Columbus, Ohio. 1 Petitioner concedes that he is liable under sec. 6662 for 1994 and 1995 relating to the settled issues.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011