FOLEY, Judge:
Respondent determined a deficiency of $18,222 and a section 6662(a) penalty of $3,644 relating to petitioners' 1995 Federal income tax. The parties submitted this case fully stipulated pursuant to Rule 122. Unless otherwise indicated, all section references are to the Internal Revenue Code (I.R.C.) in effect for the year in issue, and all Rule references are to the Tax Court Rules of...
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