Bogley v. Commissioner
United States Tax Court
In 1950 petitioners owned and resided in a home located on 13 acres of land. In December of that year they bought a new home and sold their old home, together with the 3 acres surrounding it. In 1951 they sold the remaining 10 acres in 2 transactions. Held, the gain resulting from 1951 sales not entitled to nonrecognition under section 112 (n) (1), I. R. C. 1939, as added to Code by section 318 of the Revenue Act of 1951.
1Opinion of the Court
Respondent determined a deficiency in petitioner’s income tax for the year 1951 in the amount of $5,313.02, together with additions to tax under section 294 (d) (2) and (d) (1) (A), I. R. C. 1939, in the respective amounts of $480.54 and $720.79.
By supplemental stipulation filed after the trial of this case, the respondent has conceded that petitioners are not liable for the addition to tax under section 294 (d) (2) and petitioners have conceded that the addition to tax under section 294 (d) (1) (A) is proper.
That part of the deficiency is here at issue which results from respondent’s…
2Cited by11 opinions
- O'Barr v. CommissionerUnited States Tax Court · 1965
- Gates v. CommissionerUnited States Tax Court · 2010
- Hughes v. CommissionerUnited States Tax Court · 1970
- Bogley v. CommissionerUnited States Tax Court · 1958
- Gates v. CommissionerUnited States Tax Court · 2010
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