Memorandum Findings of Fact and Opinion
WELLS, Judge:
Respondent determined deficiencies in petitioners' Federal income tax as follows:
Year Deficiency 1977 ...................... $11,068.68 1978 ...................... 5,774.00
Respondent asserts in his amendment to answer that petitioners are liable for increased interest on the deficiency under section 6621(c).
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