(petitioners' real estate transaction did not qualify for tax-deferred status under I.R.C. Sec. 1031; petitioners owned undeveloped Arizona parcel that was held for investment and sold the property with the intent to execute a Sec. 1031 exchange for California property; property was sold with petitioners receiving $10,000 and $66,000 placed in escrow account with instructions from petitioners to hold $61,743.25 to be held in escrow account; escrow agreements made no reference to Sec. 1031 and did not limit petitioners' right to receive, pledge, borrow or obtain benefits of account funds; while properties involved were like-kind, transactions involved a sale and reinvestment of proceeds in California property; petitioners constructively received proceeds of sale of Arizona property; escrow accounts were not qualified escrow accounts and transaction did not qualify for I.R.C. Sec. 1031).