MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge:
Respondent determined a deficiency in petitioner's Federal income tax in the amount of $5,500 and an accuracy-related penalty pursuant to section 6662(a) in the amount of $1,100 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 are to the Tax Court Rules of Practice and Procedure...
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