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PARKER v. COMMISSIONER

Docket No. 9590-98.

78 T.C.M. 621 (1999)

T.C. Memo. 1999-347

Lee F. Parker and Diane K. Parker v. Commissioner.

United States Tax Court.

Filed October 20, 1999.

Attorney(s) appearing for the Case

Curtis W. Berner, for the petitioners. Usha Ravi, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

NIMS, Judge:

Respondent determined a Federal income tax deficiency for petitioners' 1991 taxable year in the amount of $54,341. The sole issue for decision is whether, for purposes of section 1034, petitioners may include expenses incurred in constructing a structure intended for eventual residential use as part of the cost of their new principal residence, thereby enabling

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