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FARAH v. COMMISSIONER

Dkt. No. 23412-05.

94 T.C.M. 595 (2007)

T.C. Memo. 2007-369

J. Ramsay Farah and Elizabeth Farah v. Commissioner.

United States Tax Court.

December 19, 2007.

Attorney(s) appearing for the Case

Jurist Bruce Howard, for petitioners.

Jay A. Roberts and Ann M. Welhaf, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

Respondent determined a deficiency in petitioners' Federal income tax of $170,925 and a penalty under section 6662(a) of $34,185, for 2001.1

After concessions,2 the issues for decision are: (1) Whether petitioners may exclude the gain on the sale of their Berlin home under section 121; (2) whether petitioners may also exclude the gain...

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