MEMORANDUM OPINION
COUVILLION, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency of $6,741 in petitioners' 1990 Federal income tax and an accuracy-related penalty of $1,348.20 under section 6662(a).
The issues for decision are: (1) Whether petitioners are entitled to deductions under section 162(a) for expenses incurred from...
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