Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioner's Federal income tax as follows:
Year Deficiency 1977 $16,897.77 1978 4,219.31
These cases have been consolidated for trial, briefing, and opinion. After concessions, the only issue is whether the amount of investment tax credit allowable for certain property is limited by section 46(e).
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