§6005

ction 1250(a) ordinary income treatment of section 1250 gain recapture. Recognizing that this conflict existed, Congress included technical corrections in the Internal Revenue Service Restructuring and Reform Act of 1998 (1998 Act), Pub. L. 105-206, sec. 6005(d), 112 Stat. 800, which revised and clarified the definition of unrecaptured section 1250 gain under the 1997 Act. Under the 1998 Act, the definition of unrecaptured section 1250 gain was amended to include long-term capital gain that is -

s that the gain from the sale of the Cumberland house was properly excluded from petitioners’ gross income for 1997 pursuant to section 121. See sec. 121, enacted by sec. 312(a), Taxpayer Relief Act of 1997, Pub. L. 105-34, 111 Stat. 836 (amended by sec. 6005(e), Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, 112 Stat. 805). Additionally, petitioners purchased an unimproved lot in Cumberland County in 1980 which they sold in 1997. They reported a capital gain of