ROSS, Senior Circuit Judge.
Appellants David and Valeria Miller (taxpayers) appeal from a judgment entered in favor of the Government concluding that the taxpayers are not entitled to deduct from their gross income interest arising from an underlying income tax deficiency. After a careful review of the record, briefs and arguments of the parties, we affirm.
I.
The taxpayers were assessed federal and state income tax deficiencies for the tax years...
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