MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, Special Trial Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 2000 of $10,071, as well as an accuracy-related penalty for a substantial understatement of income tax of $2,014. The grounds for the deficiency were the limitations of section 165(d) as applied to Gloria Tschetschot's (Mrs. Tschetschot) professional...
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