What you'll have to do is put two images on top of eachother, then
fade the top one out (opacity 1 --> 0), or even fade one out (1 -->
0), and the other in (0 --> 1) so you don't have to worry about
stacking order.

Like Ryan said, you can't tween the source of an image. You can only
tween properties that can have a transition. With an image source it's
either image1 or image2, not a combination of those.

-- Tim

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