MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies of $1,435 and $8,883 in petitioners' Federal income taxes for 1990 and 1991, respectively. Respondent also determined accuracy-related penalties of $287 and $1,777 under section 6662(a) for those years. Unless otherwise indicated, 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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