MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined a $35,377 deficiency in petitioners' 1991 Federal income tax, an $18,014.38 section 6651(a)(1) addition to tax, and a $7,075 section 6662(a) accuracy-related penalty.
All section references are to the Internal Revenue Code as in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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