Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a $148 deficiency in petitioners' 1975 income tax. Petitioners, husband and wife, resided in Santa Ana, California, when they filed their petition herein, as well as during the taxable year 1975. At issue is whether petitioners are accountable for interest accruing on three bank accounts and two certificates of deposit. They had opened these bank accounts and purchased the certificates...
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