Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency in petitioners' Federal income tax for the taxable year 1978 in the amount of $20,787. After concessions, the issue for decision is whether petitioners are entitled to the investment tax credit and investment tax credit carryforwards with respect to leased motor vehicles on their return for the taxable year 1978 pursuant to section 46(e) (3) (B).
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