TIETJENS, Judge:
The Commissioner determined a deficiency in petitioner's Federal income tax for taxable year 1963 in the amount of $12,950.31. The two issues remaining for our decision are whether petitioner realized a long-term gain in taxable year 1963 upon receipt of insurance proceeds paid on the destruction of property by fire, and if so, whether petitioner is entitled under section 1033 (a) (3), I.R.C. 1954,
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