MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined an $88,376 deficiency in petitioners' 1989 Federal income tax and a $17,675 section 6662(a) accuracy-related penalty. 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 deficiency is based on an adjustment to the income of petitioners' wholly owned S corporation...
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