FORRESTER, Judge:
Respondent has determined deficiencies in petitioner's income tax in the amounts of $31,448.85 and $119,777.13 for taxable years 1964 and 1965, respectively. Petitioner claims a refund in the amount of $146,595.72 for taxable year 1964. Concessions having been made, the sole issue remaining for our decision is whether, for purposes of computing the petitioner's qualified investment eligible for the section 38
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