MEMORANDUM OPINION
HALPERN, Judge:
By notice of deficiency dated May 13, 1998 (the notice), respondent determined a deficiency in petitioners' Federal income tax for 1994 in the amount of $58,632 and an accuracy-related penalty in the amount of $11,726.40. Petitioners have conceded certain of respondent's adjustments giving rise to that deficiency. The issues remaining for decision are (1) certain adjustments by respondent to deductions claimed by petitioners...
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