MEMORANDUM OPINION
WOLFE, Special Trial Judge:
Respondent determined a deficiency in petitioner's Federal income tax for 1993 in the amount of $4,008 and an accuracy-related penalty under section 6662(a) in the amount of $797. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure...
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