MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated June 13, 1997, respondent determined a deficiency of $18,504 and a section 6662 accuracy-related penalty of $3,701 relating to petitioners' 1994 Federal income taxes. 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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