Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $20,753 in petitioners' Federal income taxes for 1978. The deficiency resulted from respondent's determination that petitioners were not entitled to deduct $40,000 depreciation claimed in relation to a master recording activity. By amendment to his answer, respondent claims additional interest under section 6621(d).
Findings...
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