MEMORANDUM FINDINGS OF FACT AND OPINION
WRIGHT, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for taxable year 1990 in the amount of $10,229, an addition to tax under section 6651(a) in the amount of $2,087, and an accuracy-related penalty under section 6662(a) in the amount of $2,045.03.
After concessions by the parties, the issues for our decision for the taxable year 1990 are:
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