MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge.
Respondent determined a deficiency in petitioners' Federal income tax of $9,187 and an accuracy-related penalty in the amount of $1,837.40 pursuant to section 6662(a) for the taxable year 1999. 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.
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