MEMORANDUM OPINION
GOLDBERG, Special Trial Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1997 in the amount of $3,937 and an accuracy-related penalty in the amount of $787.40. Unless otherwise indicated, 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.
After concessions by petitioner...
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