MEMORANDUM OPINION
DINAN, Special Trial Judge:
Respondent determined deficiencies in petitioners' Federal income taxes of $2,975 and $3,537, and accuracy-related penalties of $595 and $707.40, for the taxable years 1996 and 1997. By amended answer, respondent pled increased deficiencies and penalties for each year in issue, for deficiencies totaling $5,355 and $6,351, and penalties totaling $1,071 and $1,270, in the respective years. Unless otherwise indicated...
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