MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
Respondent determined a deficiency of $12,543 in petitioners' 1989 Federal income tax and an accuracy-related penalty pursuant to section 6662 in the amount of $475.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After a concession,
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