Memorandum Opinion
COHEN, Judge:
Respondent determined a deficiency of $22,855.59 in petitioner's Federal income tax for 1981 and additions to tax under section 6653(a)(1) and (2). Respondent has conceded that petitioner is not liable for the additions to tax under section 6653(a)(1) and (2). Respondent has also conceded that petitioner is entitled to carry back an investment tax credit to the taxable year ended December 31, 1981. Unless otherwise indicated...
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