MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined a deficiency in petitioners' 1989 joint Federal income tax of $123,028 and an addition to tax under section 6651(a)(1) of $6,151.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1989, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions by petitioners, the primary issue for...
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