MEMORANDUM OPINION
JACOBS, Judge:
Respondent determined a $19,575 deficiency in petitioners' 1989 Federal income tax, and a $3,915 section 6662(a) accuracy-related penalty for such year.
The issues for decision are: (1) Whether petitioners are entitled to a claimed $23,822.36 deduction for contributions allegedly made by or on behalf of petitioner Marcus Ramsey to a simplified employer pension-individual retirement account plan; (2) whether petitioners...
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