MEMORANDUM OPINION
COUVILLION, Special Trial Judge:
This case was heard pursuant to section 7443A(b)
Respondent determined a deficiency of $8,116 in Federal income tax and an accuracy-related penalty under section 6662(a) in the amount of $1,623 for petitioners' 1992 tax year.
After a concession by petitioners, the issues for decision are whether petitioners properly substantiated...
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