Harvey Jacobson and Marcia Jacobson v. Commissioner of Internal Revenue

MAHONEY, Circuit Judge:

Harvey and Marcia Jacobson 1 appeal from an order and decision of the United States Tax Court, B. John Williams, Jr., Judge, entered February 2,1989 that determined (1) a federal income tax deficiency for 1979 in the amount of $29,444, and (2) that the entire deficiency constituted a substantial underpayment attributable to a tax-motivated transaction for purposes of computing the interest payable with respect to the deficiency, pursuant to 26 U.S.C. § 6621(c) (1988), formerly § 6621(d). 2 The memorandum opinion of the Tax Court is reported as Jacobson v. Commissioner,…