Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined a deficiency in petitioners' 1990 Federal income tax in the amount of $13,738. Respondent further determined that petitioners were liable for the accuracy-related penalty under section 6662(a) in the amount of $2,748 for tax year 1990.
This case is presently before the Court on respondent's motion for summary judgment pursuant to Rule 121
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