MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined a deficiency of $14,036 in petitioners' Federal income tax for 1991 and an accuracy-related penalty under section 6662(a) of $2,735.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1991, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After settlement, the primary issue for decision is...
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