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WELLS v. COMMISSIONER

Docket No. 16962-93.

70 T.C.M. 1278 (1995)

T.C. Memo. 1995-537.

S. Victoria Wells v. Commissioner.

United States Tax Court.

Filed November 13, 1995.

Attorney(s) appearing for the Case

Carl F. Agren, Orange, Calif., for the petitioner. Maria D. Murphy, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined a deficiency in petitioner's 1989 Federal income tax in the amount of $150,027 and an accuracy-related penalty under section 6662(a)1 in the amount of $30,005. The issues for our consideration are: (1) Whether petitioner was the sole owner of a residence for Federal income tax purposes and, thus, required to recognize 100 percent of the gain on its disposition...

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