MEMORANDUM OPINION
KORNER, Judge:
Respondent determined a deficiency in petitioners' 1990 Federal income tax in the amount of $22,217 and a penalty under section 6662(a) in the amount of $5,281 for 1990.
All statutory references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, except as otherwise noted.
Petitioners, John Edward and Linda Hall, were...
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