MEMORANDUM OPINION
HAMBLEN, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for taxable year 1985 in the amount of $73,068. By amendment to answer, respondent asserted an increased deficiency in the amount of $81,211. Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the year at issue, and Rule references are to the Tax Court Rules of Practice and Procedure.
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