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FRIEDLAND v. COMMISSIONER

Docket No. 14267-99.

82 T.C.M. 492 (2001)

T.C. Memo. 2001-236

Joel and Paula Friedland v. Commissioner.

United States Tax Court.

Filed September 10, 2001.

Attorney(s) appearing for the Case

Samuel C. Ullman and Alex Rubio, for the petitioners. Sergio Garcia-Pages and Andrew M. Tiktin, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined a deficiency of $165,919 in and an accuracy-related penalty of $33,184 pursuant to section 6662(a)1 on petitioners' 1992 Federal income tax. The primary issue for decision is whether petitioners had a gain in 1992 on Joel Friedland's (Mr. Friedland) transfer of 6,842 shares of United Bankshares, Inc., stock pledged to United National Bank in 1991. If...

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