MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
Respondent determined a Federal income tax deficiency for petitioners' 1995 taxable year in the amount of $64,745. Respondent also determined an addition to tax of $16,295 pursuant to section 6651(a)(1) and an accuracy-related penalty of $12,949 under section 6662(a). After concessions, the sole issue for decision is the claim by Tony D. Ishizaki (petitioner...
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