MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
Respondent determined a Federal income tax deficiency for petitioners' 1993 taxable year in the amount of $93,957. Respondent also determined an addition to tax of $23,161 pursuant to section 6651(a)(1) and an accuracy-related penalty of $18,791 under section 6662(a).
The issues for decision are:
(1) Whether petitioners, having reported gross receipts of $244,270 on their 1993 Schedule...
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