Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a $7,696.74 deficiency in the Federal income tax of Jerome K. (now deceased) and Sylvia Goldstein for the taxable year 1968. The sole issue in controversy is whether petitioners' gain realized on the voluntary conversion of property in 1968 should have been recognized on their 1968 joint income tax return or whether such gain qualified for nonrecognition under section 1033....
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