Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1976 of $8,094.66. Due to concessions, the issue for decision is whether petitioner's disposition of property located at 2060 Buena Vista Avenue, Alameda, California, in 1976, qualified for nonrecognition of gain under section 1031.
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