Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
The Commissioner determined a deficiency in petitioners' 1979 Federal income tax in the amount of $29,654. The issues we must decide are: (1) whether the transaction before us was devoid of economic substance, (2) whether petitioners are entitled to deduct certain interest; and (3) whether petitioners are liable for increased interest on an underpayment attributable to a tax motivated transaction pursuant...
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