Memorandum Findings of Fact and Opinion
GERBER, Judge:
The issues in this case involve the propriety of advance rental and other deductions, and investment and energy tax credits, claimed by petitioners with respect to the lease of an energy management unit from OEC Leasing (OEC). Respondent determined a deficiency in petitioners' 1982 income taxes of $11,018, an addition to tax under section 6653(a)(1)
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