MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge.
Respondent determined a $9,483 deficiency (including a $1,990 10-percent additional tax under section 72(t)(1)) in petitioners' Federal income tax for 2002 and a $1,897 section 6662(a) accuracy-related penalty.
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 and Procedure...
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