Joel and Paula Friedland - Page 12




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          6,842 shares of the pledged stock.  Without an amount realized,             
          petitioners did not have a gain.11  See sec. 1001(a).                       
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for petitioners.                         
































               11  Therefore, we need not decide whether petitioners are              
          entitled to a deduction for this transfer or whether they are               
          liable for a penalty pursuant to sec. 6662.                                 




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