MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
Respondent determined a deficiency of $20,343 in petitioners' 1990 Federal income tax, an addition to tax pursuant to section 6651(a)(1) of $936, and an accuracy-related penalty pursuant to section 6662 of $4,069.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and...
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