MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
James E. Zurcher, Jr., petitioned the Court to redetermine respondent's determination of a $24,142 deficiency in his 1992 Federal income tax and a $4,828 penalty under section 6662(a). We must decide the following issues:
1. Whether petitioner's loss on his sale of real estate was capital or ordinary. We hold it was capital.
2. Whether petitioner is liable for the accuracy-related penalty...
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