Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined deficiencies in the income tax of petitioners for the years 1961 and 1962 in the amounts of $1,267.46 and $243.87, respectively. Concessions have been made by both parties and the only issues now remaining before us are:
1. Whether the petitioners can be allowed the benefits of the nonrecognition of gain provisions of section 1034 of the Internal Revenue Code of 1954...
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