Memorandum Opinion
HAMBLEN, Chief Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the 1989 taxable year in the amount of $13,099 and an accuracy-related penalty under section 6662 in the amount of $2,620. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the 1989 taxable year, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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