MEMORANDUM OPINION
WHALEN, Judge:
Respondent determined a deficiency of $10,209.09 in petitioners' 1978 income tax, and determined that the entire underpayment for that year is a substantial underpayment attributable to tax-motivated transactions with the result that the annual rate of interest is 120 percent of the underpayment rate, pursuant to former section 6621(c). All section references in this opinion are to the Internal Revenue Code, as amended....
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