MEMORANDUM OPINION
PAJAK, Special Trial Judge:
Respondent determined deficiencies in petitioners' 1995 and 1996 Federal income taxes in the amounts of $6,382 and $1,440, respectively, and an accuracy-related penalty under section 6662(a) in the amount of $1,276 for 1995. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue.
After a concession by respondent that petitioners are not liable...
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