IRWIN, Judge:
Respondent determined deficiencies of $270,262 and $34,564 in the income taxes of petitioner for the years 1966 and 1967, respectively. After concessions by the parties three issues remain for decision: (1) Whether petitioner's sale of its baseball stadium site to the City of Seattle was an involuntary conversion under threat of condemnation entitling petitioner to defer recognition of the gain under section 1033;
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