MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioners petitioned the Court to redetermine a $29,771 deficiency in their 1997 Federal income tax, a $4,115 addition thereto under section 6651(a)(1), and a $4,517 accuracy-related penalty under section 6662(a). We decide the only issue that petitioners raised in their petition and discussed in their brief; namely, whether the applicable 3-year period...
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