OPINION
LARO, Judge:
The parties submitted this case to the Court without trial. See Rule 122. Petitioner petitioned the Court to redetermine respondent's determination of a deficiency in tax for 1993 of $118,964, and an accuracy-related penalty for negligence under section 6662(a) of $23,793.
After concessions of the parties, we decide the following issues:
(1) Whether petitioner may deduct...
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