What is the law?

[LdiJ]

It can either be a single principal residence or they can be two potential parts of a property to sell, you can't really sell two parts and get the exclusion just because they were sold in the same year. The cases that allow for a split sale of a singularly titled property do not have the exemption applying to each part.

The code uses "principal residence". Search for synonyms in case law and you're gonna have a bad time.

("Address" is not used in the code at all. I don't see the reference on a quick search of case law. If you read the cases, it seems the use of the property is the key and not the address.)

The reason why "address" is significant in this case is because the fact that they have separate addresses shows that they are truly separate residences. Its not that the word address is going to be used in the tax code, its what the separate addresses imply.

Think a property with a main house and a guest house or a pool house with living quarters in it. That is one address, one property, and one sale to one buyer. Its unlikely that the set up would be such that the estate could even be split up if one wanted to split it up.

 

[NIV]

The reason why "address" is significant in this case is because the fact that they have separate addresses shows that they are truly separate residences. Its not that the word address is going to be used in the tax code, its what the separate addresses imply.

Think a property with a main house and a guest house or a pool house with living quarters in it. That is one address, one property, and one sale to one buyer. Its unlikely that the set up would be such that the estate could even be split up if one wanted to split it up.

Say we have a property with a house and a huge chicken coop (Or, other out buildings.) on it with one address. That is the core of the case decisions. One address, multiple uses.