Memorandum Findings of Fact and Opinion
PARR, Judge:
By notice of deficiency, respondent determined a deficiency in petitioners' 1980 Federal income tax in the amount of $8,082.92. The deficiency was due to respondent's adjustment to the capital gain reported by petitioners on the sale by petitioner Babette Barton McNulty (Babette) to petitioner John K. McNulty (John) of a one-half interest in their current residence. The issues for decision are:
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