MEMORANDUM OPINION
LARO, Judge:
The case is before the Court fully stipulated under Rule 122. Phillip Moreno petitioned the Court to redetermine respondent's determination of a $24,160 deficiency in his 1992 Federal income tax. We must decide whether petitioner's 1992 gross income includes the gain that he realized in 1992 from the sale of his personal residence. We hold it does. Unless otherwise indicated, section references are to the Internal Revenue...
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