IRWIN, Judge:
The Commissioner determined deficiencies in petitioners' income tax in the amounts of $923.67 and $3,059.68 for the years 1964 and 1965, respectively.
Petitioners did not contest certain determinations in respondent's notice of deficiency. Therefore, the issues for decision are as follows:
(1) Whether petitioners are permitted under section 1031 (a) of the Internal Revenue Code of 1954
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