MEMORANDUM OPINION
HAMBLEN, Chief Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1988 in the amount of $31,700 and an addition to tax under section 6653(a)(1) in the amount of $1,585. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the 1988 taxable year, and Rule references are to the Tax Court Rules of Practice and Procedure.
References to petitioner...
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