OPINION
PER CURIAM:
Messrs. Meyer, father and son, were general partners in a real estate partnership. They exchanged their partnership interests for a second real estate partnership in which the son was a general partner and the father was a limited partner. Both partnerships were involved in owning and renting apartments in the San Francisco area. Each claimed the exchange was of property of like kind and, therefore, nontaxable pursuant to section 1031...
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