MEMORANDUM OPINION
GOLDBERG, Special Trial Judge:
Respondent determined deficiencies in petitioner's Federal income taxes in the amounts of $82 and $17 for the taxable years 1996 and 1997, respectively. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue.
The sole issue for determination is whether petitioner is entitled to the earned income credit for the tax years 1996 and 1997.
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