- 2 -
petitioner is liable for income tax on the gain from sale of her
residence in 1995 and whether petitioner is entitled to have
interest abated on her tax liability.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Tokyo, Japan, at the time she filed her petition.
Petitioner sold her residence in Modesto, California, on
April 18, 1995. Petitioner did not make a payment of tax related
to the sale of her residence with her 1995 Federal income tax
return. Petitioner attached to her return a Form 2119, Sale of
Your Home, on which she reported a gain on the sale of $126,097.
Petitioner also indicated on the Form 2119 that she intended to
replace her home within the “replacement period”.
Petitioner moved to Japan and has lived there continuously
since April 5, 1997.
On May 12, 2000, petitioner went to respondent’s Modesto,
California, office and spoke with Group Manager Timothy Herrera.
Mr. Herrera told petitioner that she should pay the tax liability
for the 1995 sale of her residence. Petitioner paid respondent
$32,0602 for the tax liability related to the sale of her
residence.
2 All amounts are rounded to the nearest dollar.
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