- 2 -
Respondent determined a $1,760 deficiency in petitioner’s
1996 Federal income tax. The issue for decision is whether gain
realized on the sale of petitioner’s residence is excludable from
his gross income.
Background
Some of the facts have been stipulated and are so found.
Petitioner filed a timely 1996 Federal income tax return. At the
time the petition was filed, petitioner resided in Daytona Beach,
Florida.
Petitioner was born in New Jersey in 1931. Since the late
1960’s until his retirement, petitioner was employed as a truck
driver. He was married to Ann Maureen Taylor (Ms. Taylor) until
their divorce in November 1981.
In 1969, petitioner and Ms. Taylor purchased a house located
at 207 Squaw Trail, Hopatcong, New Jersey, for $21,500 (the New
Jersey residence). After substantial improvements were
completed, petitioner and Ms. Taylor moved in and raised their
four children there.
Pursuant to their divorce, petitioner and Ms. Taylor each
received a one-half interest in the New Jersey residence. Ms.
Taylor died in September 1982. Petitioner’s four children
inherited her interest in that property. On various dates
between September 1984 and December 1986, each of petitioner’s
children sold or otherwise formally transferred his or her
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011