Memorandum Opinion
HAMBLEN, Judge:
Respondent determined a deficiency of $6,900 in petitioner's 1976 Federal income tax. The issue for decision is whether two sailboats that petitioner purchased in the United States and leased for use in the British Virgin Islands qualify for the investment tax credit under section 38.
All the facts have been stipulated and are found accordingly.
Petitioner Samuel E. Kelley resided...
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