MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge:
Respondent determined a deficiency of $55,814 in petitioners' 1993 Federal income tax and a $11,163 accuracy-related penalty under section 6662(a). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issues for decision are: (1) Whether petitioners...
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