OPINION
FEATHERSTON, Judge:
Respondent determined a deficiency in the amount of $453,197 in the Federal income tax of Retlaw Enterprises, Inc. (Retlaw), of which Walt Disney Inc. (petitioner) is a successor in interest. The only issue remaining for decision is whether Retlaw is required to recapture investment tax credit for 1982 in an amount of $483,918 as a result of the transfer of certain assets to a newly formed subsidiary corporation.
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