MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge:
For the 1993 taxable year, respondent determined a deficiency of $18,806 in petitioner's Federal income tax and an accuracy-related penalty of $3,761.
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.
After concessions by the parties,
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