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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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Last modified: May 25, 2011