MEMORANDUM OPINION
HALPERN, Judge:
By notice of deficiency dated November 20, 1997 (the notice), respondent determined a deficiency in petitioner's Federal income tax for its taxable year ended September 30, 1994 (the 1994 tax year), in the amount of $63,232 and an accuracy-related penalty in the amount of $12,646.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references...
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