OPINION OF THE COURT
ALDISERT, Circuit Judge.
The question for decision is whether a husband settling a sum of $1,000,000 on his wife, pursuant to a divorce-related property settlement agreement, is entitled to a deduction under Section 483 of the Internal Revenue Code of imputed interest in the installment payments. The district court denied taxpayers' claims for refund. This appeal followed. We affirm.
The facts giving rise to this dispute are...
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