MEMORANDUM OPINION
COUVILLION, Special Trial Judge:
Respondent determined deficiencies of $5,838 and $4,349 in petitioner's Federal income taxes for 1992 and 1993, respectively, and accuracy-related penalties under section 6662(a) of $1,167 and $869 for those years.
The issues for decision are: (1) Whether, for 1992 and 1993, an activity conducted by petitioner known as the Baton Rouge Volleyball Club constituted an...
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