Memorandum Opinion
RAUM, Judge:
The Commissioner determined an $8,002 deficiency in petitioners' 1978 Federal income tax. After concessions, the principal issue for decision is whether, pursuant to section 1034, I.R.C. 1954, petitioners are entitled to defer recognition of gain realized by them on sale of their principal residence on September 22, 1978. The facts have been stipulated.
Petitioners Joel and Ruth Kerns are husband and wife. Their legal...
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