MEMORANDUM OPINION
WELLS, Judge.
Respondent determined a deficiency in petitioners' 2000 Federal income tax of $91,763, a section 6651(a)(1) addition to tax for failure to file of $9,176.30, and a section 6662 accuracy-related penalty of $18,352.60. Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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