MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined a deficiency of $25,318 in petitioner's Federal income tax for 1994 and an accuracy-related penalty of $4,916 under section 6662(a).
Unless otherwise indicated, all section references are to the Internal Revenue Code 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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