MEMORANDUM OPINION
PARR, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1993 in the amount of $60,448, an addition to tax of $15,113 under section 6651(a)(1), and a penalty of $12,090 under section 6662(a). All section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated...
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