No Gain Exclusion on Home Sale Because Taxpayers Never Lived in It.

The petitioners, a married couple, bought a home in 1994 for $200,000.  They used the home as a group home for disabled persons.  The petitioners resided in another home in a different town, and it was this home's address that was used on the petitioners checks, payroll records, their kids' school records, etc.  The petitioner's sold the group home in 2007 for $600,000 and sought to exclude the gain under I.R.C. Sec. 121.  The court, agreeing with the IRS, denied the exclusion because there was no evidence that the petitioners ever lived in the group home and used it as their principal residence.  Villegas v. Comr., T.C. Memo. 2015-33.  .