NIAGARA COUNTY SAVINGS BANK v. COMMISSIONER

Docket Nos. 23612-81, 26339-82.

48 T.C.M. 51 (1984)

T.C. Memo. 1984-247

Niagara County Savings Bank v. Commissioner.

United States Tax Court.

Filed May 27, 1984.


Attorney(s) appearing for the Case

Jerome D. Adner and Albert R. Mugel, for the petitioners. Louis J. Zeller, Jr., for the respondent.


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).1

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