Respondent determined a deficiency in the income tax liability of petitioners for the year 1951 in the amount of $1,314.52. That part of the deficiency is here in issue which results from respondent's determination that the gain realized by petitioners on the sale of real estate in that year did not meet the requirements of section 112 (n) of the Internal Revenue Code of 1939, relating to the nonrecognition of gain from the sale or exchange of a residence, but was taxable...
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