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KIRST v. COMMISSIONER

Docket No. 22189-95.

74 T.C.M. 264 (1997)

T.C. Memo. 1997-353

Randall L. Kirst v. Commissioner.

United States Tax Court.

Filed July 31, 1997.

Attorney(s) appearing for the Case

Curt R. Craton, Long Beach, Calif., for the petitioners. Willis B. Douglass, for the respondent.

MEMORANDUM OPINION

WRIGHT, Judge:

Respondent determined a deficiency of $25,561 in petitioners' Federal income tax for taxable year 1990. Respondent further determined that petitioners are liable for the accuracy-related penalty under section 6662(a)1 in the amount of $5,112. After concessions, the issues for decision are:

(1) Whether petitioners may defer recognition of gain realized from the sale of petitioner husband...

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