OPINION
TIETJENS, Judge:
The Commissioner determined deficiencies in income tax as follows: 1962, $236.43; 1963, $1,089.35.
The petitioners claim an overpayment of $1,239.63 in income taxes for 1962.
The sole issue is whether all or any part of the systems used to furnish water, gas, electricity, and sewage disposal services to occupants of petitioners' trailer park are section 38 property as defined in section 48(a)(1) of the Internal...
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