ATKINS, Judge:
The respondent determined deficiencies in income tax of petitioners in the amounts of $111,707.80 for the year 1958 and $1,417.90 for the year 1960. The parties have reached agreement as to all issues for 1960 and all issues for 1958 except the issue of whether the transfer by petitioners in 1958 of a parcel of realty and the acquisition of another constituted a nontaxable exchange within the meaning of section 1031 of the Internal Revenue Code...
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