MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined a deficiency in petitioners' 1992 Federal income tax of $27,898 and an addition to tax of $6,974 under section 6651(a)(1) for failure to file timely.
After concessions, the issues for decision are:
1. Whether petitioners may exclude $125,000 of the gain from the sale of their principal residence in 1992 under section 121. We hold that they may not.
2. Whether...
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