Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
Respondent determined a deficiency in petitioners' Federal income tax in the amount of $10,111.16 for taxable year 1988.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. For taxable year 1988, the issues for decision are:
(1) Whether petitioners...
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