OPINION
DYER, District Judge.
This is a tax refund case. Plaintiffs seek to qualify certain transactions made in 1959 as a § 1031 tax-free exchange. The facts are fully stipulated.
Thad H. Carlton, hereinafter referred to individually as decedent, and June Carlton, hereinafter jointly referred to as plaintiffs, were, during the calendar years 1959 and 1960, husband and wife with their principal place of residence at 1707 South Indian River Drive...
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