Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $16,329 in petitioners' Federal income taxes for 1988 and an $816.45 addition to tax under section 6653(a). The issues for decision are whether petitioners are entitled to roll over the gain from the sale of a residence; the amount of depreciation that petitioners are entitled to deduct on a mobile home; and whether petitioners are liable for the section 6653(a) negligence...
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