Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
The Commissioner determined deficiencies in petitioners' Federal income tax liability for the calendar years 1974, 1975, 1976, and 1978 in the following amounts, respectively: $6,260, $3,132, $604, and $1,731. By motion for leave to amend answer, filed November 6, 1985, respondent claims additional interest under section 6621(d)
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