MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioners' Federal income tax of $51,944 for 1991 and $12,672 for 1992 and accuracy-related penalties of $10,389 for 1991 and $2,534 for 1992.
After concessions, the issues for decision are:
1. Whether petitioners are exempt from Federal income tax. We hold that they are not.
2. Whether petitioners may deduct advertising expenses for selling...
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