J. Ramsay Farah and Elizabeth Farah - Page 2

               After concessions,2 the issues for decision are:  (1)                  
          Whether petitioners may exclude the gain on the sale of their               
          Berlin home under section 121; (2) whether petitioners may also             
          exclude the gain on the sale of the South Point Road lot under              
          section 121; and (3) whether petitioners are liable for a penalty           
          under section 6662(a).                                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, the exhibits attached thereto, and the            
          stipulation of settled issues are incorporated herein by this               
          reference.   At the time they filed their petition, petitioners             
          resided in Hagerstown, Maryland.                                            
               In 1976, petitioner Dr. J. Ramsay Farah (Dr. Farah) opened             
          his pediatric medical practice in Hagerstown, Maryland.3  Over              
          the years, petitioner Elizabeth Farah (Ms. Farah) also worked for           
          the medical practice assisting with various administrative                  
          duties.  However, she always worked from her home.                          

               2Petitioners concede they are not entitled to a loss of                
          $45,733 from their Schedule E, Supplemental Income and Loss,                
          rental real estate activities, and they are not entitled to                 
          Schedule C, Profit or Loss From Business, deductions of $64,915.            
          Petitioners also concede they failed to report State income tax             
          refunds of $3,354.                                                          
               3At various times from 1980 through 1998, Dr. Farah operated           
          medical offices in Waynesboro, Pennsylvania, and Boonsboro,                 
          Maryland, in addition to his Hagerstown practice.                           

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next 

Last modified: March 27, 2008