United States Tax Court.
MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge.
Respondent determined a deficiency in petitioners' 2001 Federal income tax and a penalty as follows:
Deficiency Sec. 6662(a) Penalty
$32,804 $6,561
Unless otherwise indicated, 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...
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