MEMORANDUM OPINION AND ORDER
BUCKLO, District Judge.
On their income tax returns for 1995 and 1996, Bruce F. Johnson and Judy E. Johnson paid income tax deficiencies and interest related to those tax deficiencies to the Internal Revenue Service ("IRS"). Plaintiffs later filed amended tax returns seeking a refund based on the ground that they were entitled to deduct interest they had paid to the IRS during those years. The IRS rejected the plaintiffs...
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