United States Tax Court.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined a deficiency in petitioner's 1994 Federal income tax of $59,914 and an addition to tax of $14,979 under section 6651(a)(1) for failure to file a timely income tax return for 1994.
After concessions, the issues for decision are:
1. Whether petitioner had a capital gain of $71,001 on the sale of his personal residence...
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