MEMORANDUM OPINION
NAMEROFF, Special Trial Judge:
Respondent determined a deficiency in petitioners' 1995 Federal income tax in the amount of $3,851 plus an accuracy-related penalty under section 6662(a) of $770.20. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Court's Rules of Practice and Procedure.
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