MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
For petitioners' taxable (calender) year 1990, respondent determined a deficiency in petitioners' Federal income tax liability of $28,694 and an accuracy-related penalty of $371.
The issues remaining for decision are: (1) Whether, during 1990, petitioner husband was a shareholder in an S corporation so that petitioners are required to report his pro rata share of the corporation's income and...
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