MEMORANDUM OPINION
NIMS, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for 1993 in the amount of $11,129, and an accuracy-related penalty under section 6662(a) for 1993 in the amount of $2,226. All section references are to sections of the Internal Revenue Code in effect for 1993, and all Rule references are to the Tax Court Rules of Practice and Procedure.
There are two issues for decision. The first is whether petitioner...
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