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Question

My home was flooded in 1998. My employment involved me to work many extended hours and travel away from home was near 70% some years. When I did get time to work on the home, it took so much extra effort to work around living in it and major renovation at the same time that progress was very slow. In 2004 we had take in an elderly family member and we had actually outgrown the house so we figured a way to buy another house that would better fit us. Part of the plan was that with the flooded house empty it would make repairs go much quicker. We could sell it and relieve the financial strain of having two properties.. Due to my travel and workload it took 2 ½ years to finish enough to put it on the market. A foundation issue surfaced and the market passed over the house until that and some other repair was finally finished. When the repaired flooded property sold, we had been out of it for 3 ½ years. We discovered at 3 years 1 month that the tax law would require us to pay taxes since we had been out of the house 3 out of 5 years. The law stated that the IRS could grant exceptions to that rule, my question is how do I approach the IRS to find out as soon as possible that my situation would allow for an exception and not require the tax paid. We already have suffered enough loss through the whole ordeal and the money is needed badly.

Submitted: 451 days and 4 hours ago.
Category: Tax
Value: $30
Status: CLOSED
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Optional Information

New Braunfels Texas, United States

Posted by RD 451 days and 4 hours ago.

Info Request

Did you live in the house as your primary residence for atleast 2 years in the 5 years preceding the sale?

Did you have any other primary residence? Was the house not habitable due to flooding?

 

451 days and 4 hours ago.

Reply

We no longer slept in the flooded house as of 01/01/2005. We had not finished moving all of our belongings until the sale close date 08/01/2008, However 80 % of our personal property was out by 02/28/2005
    The house was biologically safe as of 01/01/1999. In terms of other safe, it was a construction zone while we lived in it. Exposed and loose boards, nails, tools etc. There were few inner doors in place( we would move wood in front of the door openings at night). We lived in it because we had no other choice at the time. After we moved out, the doors, trim, cabinets, final wall finishing etc was mostly done by 03/20/2007. It would probably not have been considered as “safe” until that time.

451 days and 3 hours ago.

Reply

To clarify the primary residence question, we have never owned more than one home at a time orther than this situation were we could not sell the flooded home until all repairs were done. If I had known there was a law that would make us run out of time We would have gone with out sleep and or taken time off without pay to get done in time. we missed the two out of five rule by about 6 months. I am curious when the 2 out of 5 rule started?

Posted by RD 450 days and 22 hours ago.

Answer

The 2 out of 5 rule starts from the date of sale of the property. In the 5 years preceding the sale, if you have used the property as your primary residence for atleast 2 years than you will be able to exclude gain upto $250K(twice if married filing jointly).

 

I would suggest you calculate your gain on sale of the house. Considering your original cost basis and improvements made to the house to make it saleable, there may not be any gain. Note that any insurance reimbursement and loss deduction taken on the tax return will reduce your cost basis.

 

 

Let me know if you have any question.

 

Please note: This advice is provided with the understanding that all the relevant facts have been provided by you. Any change in facts might affect the advice given and hence may not be relied on in such cases. Nothing contained in this reply was intended or written to be used, can be used by any taxpayer, or may be relied upon or used by any taxpayer for the purposes of avoiding penalties that may be imposed on the taxpayer under the Internal Revenue Code of 1986, as amended.

 

450 days and 18 hours ago.

Reply

You have not told me any thing that I did not know from my JK Lasser book. I clearly said "My question is"Quote from above "My question is how do I approach the IRS to find out as soon as possible that my situation would allow for an exception and not require the tax paid?" JK Lasser information states unforseen situations can be reviewed by the IRS for a ruling on an exception. I was trying to find out how to talk to the IRS so I know as soon as possible how they would rule in this case. I went to the IRS site after I saw your answer was information relevant to the sale of the home but not the answer to my question. I discovered that they have a walk in tax help office just 25 miles from my house, I had not known that they offered that service, I can set appointment and take my information to them. If I do not accept the answer am I thought of as a moocher who does not accept when future questions are asked? I have used the service once before and got a relevant answer and paid and tipped.

Posted by RD 450 days and 9 hours ago.

Answer

You do not have to accept the answer unless you are satisfied.

 

You can consider that you were not able to use the house as a primary residence due to unforseen circumstances but I would suggest you to get a second opinion too. IRS does not provide detailed situations that may be considered as unforseen circumstance. Hence, it is difficult to say if your situation would be considered as being covered under unforseen circumstance. It would be a good idea to get an answer from the IRS help desk if they can offer such advise.

 

Section 1.121-3(a) of the regulations provides for taxpayers who fail to satisfy the ownership and use tests or the limit of one sale every two years, section 121(c) of the Code provides for a reduced maximum exclusion if the primary reason for the sale is a change in place of employment, health, or unforeseen circumstances.

 

Section 1.121-3(e) of the regulations provides that a sale is by reason of unforeseen circumstances if the primary reason for the sale is the occurrence of an event that the taxpayer could not reasonably have anticipated before purchasing and occupying the residence. A taxpayer's reason for the sale is deemed to be unforeseen circumstances if one of the safe harbor events, such as death, divorce, or multiple births from the same pregnancy, occurs during the period of the taxpayer's ownership and use of the residence as the taxpayer's principal residence. In addition, the Commissioner may designate other events or situations as unforeseen circumstances in published guidance of general applicability or may issue rulings addressed to specific taxpayers identifying other events or situations as unforeseen circumstances with regard to those taxpayers.

 

Section 1.121-3(b) of the regulations provides that if a safe harbor does not apply, a sale is by reason of unforeseen circumstances only if the primary reason for the sale is unforeseen circumstances. Factors that may be relevant in determining the taxpayer's primary reason for the sale include (but are not limited to) the extent to which (1) the sale and the circumstances giving rise to the sale are proximate in time; (2) the suitability of the property as the taxpayer's principal residence materially changes; (3) the taxpayer's financial ability to maintain the property is materially impaired; (4) the taxpayer uses the property as the taxpayer's residence during the period of ownership of the property; (5) the circumstances giving rise to the sale are not reasonably foreseeable when the taxpayer begins using the property as the taxpayer's principal residence; and (6) the circumstances giving rise to the sale occur during the period of the taxpayer's ownership and use of the property as the taxpayer's principal residence.

 

Hope this helps...

 

 

Let me know if you have any question.

 

Please note: This advice is provided with the understanding that all the relevant facts have been provided by you. Any change in facts might affect the advice given and hence may not be relied on in such cases. Nothing contained in this reply was intended or written to be used, can be used by any taxpayer, or may be relied upon or used by any taxpayer for the purposes of avoiding penalties that may be imposed on the taxpayer under the Internal Revenue Code of 1986, as amended.

 

Accepted Answer

Based on comment from another expert, I would like to add that...

 

You can create a case for reduced maximum exclusion under the specific even safe harbor as outlined in Publication 523...and be able to exclude gain on sale of the home.

 

Link below

 

http://www.irs.gov/publications/p523/ar02.html#d0e3182

 

Extract from the publication-

 

Unforeseen Circumstances

The sale of your main home is because of an unforeseen circumstance if your primary reason for the sale is the occurrence of an event that you could not reasonably have anticipated before buying and occupying your main home. You are not considered to have an unforeseen circumstance if the primary reason you sold your home was that you preferred to get a different home or your finances improved.

Specific event safe harbors. Unforeseen circumstances are considered to be the reason you sold your home if any of the following events occurred while you owned and used the property as your main home.

  1. An involuntary conversion of your home, such as when your home is destroyed or condemned.

  2. Natural or man-made disasters or acts of war or terrorism resulting in a casualty to your home, whether or not your loss is deductible.

  3. In the case of qualified individuals (listed earlier under Change in Place of Employment):

    1. Death,

    2. Unemployment (if the individual is eligible for unemployment compensation),

    3. A change in employment or self-employment status that results in the individual's inability to pay reasonable basic living expenses (listed under Reasonable basic living expenses, next) for his or her household,

    4. Divorce or legal separation, or

    5. Multiple births resulting from the same pregnancy.

  4. An event the Commissioner of IRS determined to be an unforeseen circumstance in published guidance of general applicability. For example, the Commissioner determined the September 11, 2001, terrorist attacks to be an unforeseen circumstance.

 

Let me know if you have any question.

 

Please note: This advice is provided with the understanding that all the relevant facts have been provided by you. Any change in facts might affect the advice given and hence may not be relied on in such cases. Nothing contained in this reply was intended or written to be used, can be used by any taxpayer, or may be relied upon or used by any taxpayer for the purposes of avoiding penalties that may be imposed on the taxpayer under the Internal Revenue Code of 1986, as amended.

 

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Expert: RD
Pos. Feedback: 99.4 %
Accepts: 
Answered: 8/29/2008

Certified Public Accountant (CPA)

CPA, MBA, Over 10 yrs of experience in tax planning and business consulting..

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