OPINION
REBECCA BEACH SMITH, District Judge:
Appellants challenge on appeal three aspects of the Tax Court's decision: 1) the finding that appellants did not enter the master recording lease program with a profit motive; 2) the reliance upon certain expert testimony to establish the fair market values of the master sound recordings; and 3) the imposition of additional interest pursuant to section 6621(c) of the Internal Revenue Code ("I.R.C.").
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