MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for 1987 in the amount of $14,367, and an addition to tax for that year under section 6651(a)(1) in the amount of $3,204.
All section references are to sections of the Internal Revenue Code in effect for 1987, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions, the issues remaining...
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