MEMORANDUM OPINION
DEAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) of the Code and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners' 1991 Federal income tax in the amount of $5,018 and an accuracy-related penalty under section 6662(a) in the amount of $1,004.
The issues for decision are: (1) Whether petitioners are entitled to deduct for...
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