MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioners petitioned the Court to redetermine Federal income tax deficiencies of $13,517 for 1994 and $14,407 for 1995 and accuracy-related penalties of $2,703 for 1994 and $2,881 for 1995 for substantial understatement of income tax. Following concessions,
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