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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