MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge.
Respondent determined a deficiency of $146,316 in petitioners' 2001 Federal income tax, as well as an accuracy-related penalty under section 6662(a) and (d) of $29,263 for substantial understatement of income tax. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue. After concessions, the issues for decision are: (1) Whether any portion or...
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