MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
Respondent determined a Federal income tax deficiency for petitioners' 1994 taxable year in the amount of $291,931. Respondent also determined an accuracy-related penalty of $58,386 for 1994, pursuant to section 6662(a).
The issues for decision are as follows:
(1) Whether petitioners are entitled to deduct a net casualty loss of $751,427 for the taxable year 1994; and
(2) whether...
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