Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency of $44,405 in the petitioners' Federal income tax for 1980. After concessions by the parties, the only issue for decision is whether the petitioners are entitled to a deduction for depreciation for water drainage systems located beneath the surface of farms purchased by the petitioners individually and as members of a partnership and an investment tax credit...
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