Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined a deficiency in petitioners' Federal income tax of $30,250 for the tax year ended December 31, 1981. After concessions, the sole issue for decision is whether petitioners' disposition of their 309-acre farm located in Clark County, Missouri, in March 1981, qualifies, at least in part, for nonrecognition of gain under section 1031.
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