DE OCAMPO v. COMMISSIONER

Docket No. 11624-94.

73 T.C.M. 2490 (1997)

T.C. Memo. 1997-161

James P. De Ocampo and Marla L. De Ocampo v. Commissioner.

United States Tax Court.

Filed April 1, 1997.


Attorney(s) appearing for the Case

A. Nathan Zeliff, for the petitioners.1 Patricia Anne Golembiewski, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined a $38,819 deficiency for 1989 and a $7,764 accuracy-related penalty under section 6662(a).

The issues for decision are: (1) Whether petitioners may defer recognition of gain from the sale of their former principal residence under section 1034(a) when title to their new residence was acquired by the parents of petitioner James De Ocampo, and (2) whether petitioners are liable...

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