MEMORANDUM FINDINGS OF FACT AND OPINION
PANUTHOS, Chief Special Trial Judge:
Respondent determined a deficiency in petitioner's Federal income tax of $6,243 and an accuracy-related penalty under section 6662(a) of $1,249 for the 2000 taxable year. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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