MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge:
Respondent determined a deficiency of $10,756 in petitioners' 1995 Federal income tax and an accuracy-related penalty in the amount of $2,151 pursuant to section 6662. 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.
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