Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined, in an amendment to his answer, a deficiency in petitioners' 1980 Federal income tax in the amount of $19,816.95. After concessions, the issues are (1) whether the sale of a limited partnership interest and the purchase of condominium apartments are a single transaction, and (2) the character and amount of gain or loss from such sale and purchase, whether or not a single transaction...
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