OPINION
VASQUEZ, Judge.
In the notice of deficiency, respondent determined deficiencies of $38,145 and $79,812 in petitioner's Federal income taxes for 1992 and 1993, respectively. After concessions, the issue for decision is whether gain from the sale of stock pledged as collateral for a letter of credit which guaranteed petitioner's underwriting activities is portfolio income.
Unless otherwise indicated, all section references are to the...
Let's get started
Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.
