Memorandum Findings of Fact and Opinion
SWIFT, Judge:
On April 9, 1991, respondent mailed a notice of deficiency to petitioners in which respondent determined a deficiency of $57,490 in petitioners' 1987 joint Federal income tax.
All section references are to the Internal Revenue Code in effect for the year in issue.
The primary issues for decision relate to the proper calculation and accrual of statutory interest under section 6601 on taxes...
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