-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. Background 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 NextLast modified: March 27, 2008