Murphy v. Commissioner
United States Tax Court
T and his wife realized a gain on the sale of their jointly owned residence in December 1988. In their joint return they did not report the gain as gross income but deferred recognition of the gain, pursuant to sec. 1034, I.R.C., by indicating their intention on Form 2119 to purchase another residence within the 2-year period permitted by sec. 1034, I.R.C.
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T and his wife realized a gain on the sale of their jointly owned residence in December 1988. In their joint return they did not report the gain as gross income but deferred recognition of the gain, pursuant to sec. 1034, I.R.C., by indicating their intention on Form 2119 to purchase another residence within the 2-year period permitted by sec. 1034, I.R.C. Thereafter, T and his wife were separated in December 1989, and were later divorced in May 1991. However, subsequent to the separation, but within the 2-year period, T purchased a personal residence for himself. He then filed an amended…
1Opinion of the Court
William H. Murphy, Petitioner v. Commissioner of Internal Revenue, Respondent
Murphy v. Commissioner
Docket No. 10275-92
United States Tax Court
103 T.C. 111; 1994 U.S. Tax Ct. LEXIS 56; 103 T.C. No. 8;
August 2, 1994, Filed
Decision will be entered under Rule 155.
T and his wife realized a gain on the sale of their jointly owned residence in December 1988. In their joint return they did not report the gain as gross income but deferred recognition of the gain, pursuant to sec. 1034, I.R.C., by indicating their intention on Form 2119 to purchase another residence within the 2-year period permitted by…
2Cases cited13 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Enoch v. CommissionerUnited States Tax Court · 1972
- Sonnenborn v. CommissionerUnited States Tax Court · 1971
- Axelrod v. CommissionerUnited States Tax Court · 1971
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