WELLS, Judge:
Respondent determined a deficiency in petitioners' 1993 Federal income taxes of $977,267 and a section 6662 accuracy-related penalty of $195,453.
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.
The issues we must decide in the instant case are: (1) Whether section 7701(h)(1) precludes...
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