Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined income tax deficiencies against petitioners Stuart and Gretchen Gibson in the amounts of $1,716 and $985 for 1976 and 1977, respectively. After concessions, the issues for decision are: (1) Whether a disposition of one investment property in 1976 and acquisition of another such property in 1976, by a partnership in which petitioners had a one-half interest, qualifies as as an...
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