MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined a $12,952 deficiency in petitioners' 1993 Federal income tax and a section 6662(a) accuracy-related penalty. Following concessions by petitioners, the issues for decision are (1) whether petitioners must include as income the gain realized from the sale of their residence in 1993, and (2) if that gain is includable in petitioners' 1993 income, then whether petitioners' failure to...
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