OPINION
MULRONEY, Judge:
Respondent determined deficiencies in petitioners' income taxes for the years 1961 and 1962 in the respective amounts of $431.19 and $275.13.
Petitioners received capital gain upon the sale of a portion of the 2-acre tract on which their dwelling house was located. The issue is whether the gain is to be recognized when they invested the proceeds of the sale in a new residence and moved into it within 18 months after...
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