MEMORANDUM OPINION
HAMBLEN, Judge:
Respondent determined a deficiency in petitioners' 1991 Federal income tax of $25,281 and an accuracy-related penalty of $4,870 pursuant to section 6662(a). 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, the principal issue for decision is whether the lump...
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