MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
By deficiency notice dated November 10, 2004, respondent determined a deficiency in petitioners' income tax for 2002 in the amount of $20,475, and a penalty under section 6662(a) and (b)(1) in the amount of $4,095. Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for all relevant times hereunder. Rule references are to Rules contained in the Tax...
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