MEMORANDUM OPINION
COLVIN, Judge:
This matter is before the Court on respondent's motion for summary judgment. For reasons stated below, we grant respondent's motion.
Respondent determined a deficiency in petitioners' Federal income tax for 1992 of $8,758 and determined that petitioners are liable for the accuracy-related penalty for negligence under section 6662(a) in the amount of $1,752. Neither party requested a hearing and we conclude that none...
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