OPINION
SCOTT, Judge:
This case is before us on respondent's motion for summary judgment. The issue raised by respondent's motion is whether petitioners are entitled to an energy tax credit with respect to a water-source heat pump installed in 1980.
At the hearing on respondent's motion, the parties agreed to all the facts necessary to a decision of the issue presented here. Since there is no issue of material fact in this case, its disposition...
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