T.C. Memo. 2001-236 UNITED STATES TAX COURT JOEL AND PAULA FRIEDLAND, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14267-99. Filed September 10, 2001. Samuel C. Ullman and Alex Rubio, for petitioners. Sergio Garcia-Pages and Andrew M. Tiktin, for 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 1 All section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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