CHABOT, Judge:
Respondent determined a deficiency in Federal individual income tax against petitioners for 1975 in the amount of $7,736.85. The issues for decision are as follows:
(1) Whether respondent should be equitably estopped from disallowing a portion of petitioners' claimed foreign tax credit because of petitioner-husband's asserted reliance on advice understood by petitioner-husband as having been given to him by respondent's agents; and
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