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SCHLANG v. COMMISSIONER

Docket No. 7966-91.

64 T.C.M. 670 (1992)

T.C. Memo. 1992-515

Lawrence H. and Shirley A. Schlang v. Commissioner.

United States Tax Court.

Filed September 8, 1992.

Attorney(s) appearing for the Case

Kevin J. Mirch, 350 S. Center St., Reno, Nev., for the petitioners. Fred E. Green, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined deficiencies of $10,051 and $1,138 in petitioners' Federal income taxes for 1981 and 1984, respectively.

After a concession by respondent,1 the issue for decision is whether petitioners are entitled to a $1,138 investment credit for 1984 pursuant to section 382 and a resulting carryback of

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