MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $32,389 for 1990 and $15,484 for 1991, and accuracy-related penalties for negligence pursuant to section 6662 in the amounts of $6,478 for 1990 and $3,097 for 1991.
All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules...
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