MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
Respondent determined a Federal income tax deficiency for petitioners' 1996 taxable year in the amount of $71,091.00. Respondent also determined an accuracy-related penalty of $14,218.20 for 1996, pursuant to section 6662(a).
After a concession by respondent, the issues for decision are:
(1) Whether petitioners are entitled to offset gross profits reported on their 1996 Schedule C, Profit...
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