MEMORANDUM OPINION
WOLFE, Special Trial Judge:
Respondent determined a deficiency in petitioners' Federal income tax in the amount of $2,976 and an accuracy-related penalty pursuant to section 6662(a) in the amount of $595 for the taxable year 1995.
Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue.
This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction...
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