MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Chief Judge:
Respondent determined a deficiency of $46,283 in petitioners' Federal income tax for 1995. Unless otherwise indicated, section references are to sections of the Internal Revenue Code, as amended, and Rule references are to the Tax Court Rules of Practice and Procedure. The deficiency is attributable to an adjustment to the taxable income reported by EJKC, Inc. (EJKC), an S corporation of which petitioner...
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