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BEALL v. COMMISSIONER

Docket No. 18922-94.

75 T.C.M. 1873 (1998)

T.C. Memo. 1998-82

Terry Duane Beall and Joyce Engel Beall v. Commissioner.

United States Tax Court.

Filed February 25, 1998.

Attorney(s) appearing for the Case

Paul Martin Shimoff, for the petitioners. Jonathan H. Moss, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WRIGHT, Judge:

Respondent determined an income tax deficiency for petitioners' 1989 taxable year in the amount of $140,882. Respondent also determined an accuracy-related penalty for negligence under section 6662(a)1 in the amount of $28,182. The issues for decision are (1) whether petitioners are entitled to roll over the gain on the sale of their residence under section 1034, and (2)...

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