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other court, and this opinion shall not be treated as precedent
for any other cases.
The Court issued a bench opinion in this case on November
16, 2006, and directed therein that the decision be entered
pursuant to the procedures set forth in Rule 155 of the Tax Court
Rules of Practice and Procedure. In accordance with those
procedures, each party submitted a computation of the deficiency.
Respondent’s Computation for Entry of Decision was filed March
21, 2007. Petitioners’ Alternative Computation for Entry of
Decision was filed April 5, 2007. Respondent’s Reply to
Petitioners’ Alternative Computation for Entry of Decision,
referred to herein as respondent’s revised computation, was filed
June 15, 2007. The case is before the Court to resolve the
differences between the parties regarding the amount of the
deficiency to be entered by the Court.
Respondent’s original computation asks the Court to
redetermine a deficiency for 2002 of $10,246 and to redetermine
petitioners’ liability for a penalty of $2,049.20 under section
6662(a). Respondent’s revised computation concedes that the
original computation is incorrect on a number of points.
Respondent’s revised computation asks the Court to decide that
there is a deficiency of $5,913 in petitioners’ income tax for
2002, as computed in respondent’s revised computation, and to
decide further that petitioners are liable for an accuracy-
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