Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined a $31,269 deficiency in petitioners' income tax for 1972. At the time of trial, respondent filed an amendment to his answer claiming an increased deficiency of $44,449 (resulting in total income tax deficiency asserted of $75,718) for 1972. The primary issue is whether petitioners in 1972 prepaid 360 days interest due for the entire term of their loan or whether they have received...
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