OPINION
HAMBLEN, Chief Judge:
By statutory notice of deficiency dated March 6, 1992, respondent determined a deficiency in petitioners' Federal corporate income tax for the taxable year ending June 30, 1988, in the amount of $150,123. Pursuant to the provisions of section 48.4041-7, Manufacturers & Retailers Excise Tax Regs., respondent contends that petitioners are not entitled to an income tax credit under section 34 in respect of excise tax...
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