MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge:
Respondent determined a deficiency in petitioners' Federal income tax in the amount of $1,379 for the taxable year 1994. Respondent also determined petitioners were liable for an accuracy-related penalty under section 6662(a) in the amount of $148 for the taxable year 1994. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references...
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