MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent, by notice of deficiency, determined that petitioner is liable for a deficiency in his 1989 Federal income tax and an addition to tax in the amounts of $38,405 and $7,681, respectively. The issues for decision are: (1) Whether the gain realized by petitioner from the sale of his principal residence qualifies for nonrecognition treatment under section 1034(a);
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