TACHA, Circuit Judge.
John S. Rendall and his wife, Christobel D. Rendall, appeal from a decision of the United States Tax Court assessing a $259,874 deficiency in the Rendalls' income tax for the taxable year 1997. The decision was based on the Tax Court's determination that gains from the sale of stock pledged as collateral for a loan are taxable to the Rendalls and must be calculated under the first-in/first-out ("FIFO") method, see 26 C.F.R. § 1.1012...
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