FAY, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the calendar years 1962 and 1963 in the amounts of $4,736.68 and $13,046.88, respectively.
The sole issue for determination is whether petitioners are entitled to utilize the nonrecognition provisions of section 1034 of the Internal Revenue Code of 1954 with respect to the sale of their old residence.
FINDINGS OF FACT
Some of the facts have been...
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