MEMORANDUM OPINION
WOLFE, Special Trial Judge:
Respondent determined a deficiency of $4,155 in petitioners' 1998 Federal income tax. In the answer to the petition respondent asserted an accuracy-related penalty of $831 pursuant to section 6662(a). At trial respondent filed a written motion for a penalty under section 6673(a)(1). All section references are to the Internal Revenue Code in effect for 1998....
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