Joel and Paula Friedland - Page 1

                                 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.                       

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