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undeveloped land to individuals, real estate companies, and

developers.

In 1974, petitioner and Mrs. Wood purchased a house in

Annandale,

Virginia

(the

Virginia

house),

for

$57,000.

They

resided in the Virginia house until petitioner retired from the

military in 1977.

In 1976, petitioner and Mrs. Wood purchased undeveloped land

in

Florida.

The

land

remained

undeveloped

through

the

years

at

issue.

When petitioner retired from the military in 1977, he and

Mrs.

Wood

moved

to

New

Jersey.

They

sold

the

Virginia

house

for

$70,000 (incurring closing costs of $3,000 on the sale) and

purchased a house in Warren, New Jersey (the New Jersey house),

for

$87,900

(incurring

closing

costs

of

$1,214.25).

Petitioner

and Mrs. Wood did not report the gain from the sale of the

Virginia

house

on

their

1977

Federal

income

tax

return.

While

living in the New Jersey house, they made capital improvements

costing $153,435.

In 1977, petitioner and Mrs. Wood purchased a 1-week

timeshare unit in Brookdale, Pennsylvania (the Brookdale

timeshare), for $7,900.

After petitioner moved to New Jersey, he was employed first

by

Lockheed

Electronics

and

then

by

ITT

Avionics.

In

1981,

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