MEMORANDUM OPINION
WRIGHT, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for taxable year 1988 in the amount of $21,486.55.
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. After concessions by both Parties, which will be given effect in the Rule 155 computation, the issues...
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