WILES, Judge:
Respondent determined a deficiency in petitioners' income tax for the taxable year 1966 in the amount of $34,011.89. Several issues have been settled by the parties. The remaining issues are (1) whether petitioner retained a substantial interest in a corporation for purposes of determining the applicability of the recapture of investment credit provisions under section 47(a)(1), I.R.C. 1954,
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