Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined deficiencies in petitioners' Federal income tax return as follows:
Year Deficiency 1978 ............. $6,055.36 1979 ............. 9,042.17
The issue for decision is whether petitioners are taxable on interest paid pursuant to an "Agreement for Warranty Deed" which petitioners had previously transferred...
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