DRENNEN, Judge:
Respondent determined a deficiency of $19,385 in petitioners' income tax for the taxable year ended December 31, 1974.
Due to concessions, the only issue for decision is whether petitioners' transfer of their interest in a 239-acre farm and acquisition of a 645-acre farm constituted an exchange which qualifies for nonrecognition of gain, except to the extent of boot, under section 1031, I.R.C. 1954.
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