MEMORANDUM OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioners' Federal income tax of $12,925 for 1989 and $13,294 for 1991.
The sole issue for decision is whether petitioners may defer the gain realized on the sale of their old principal residence under section 1034. We hold that they may not. In so holding, we conclude that petitioners failed to establish that they sold their old residence less than 2 years after they bought...
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