Memorandum Findings of Fact and Opinion
WOLFE, Special Trial Judge:
This case was heard pursuant to the provisions of section 7456(d) of the Internal Revenue Code.
Respondent determined a deficiency in petitioners' 1981 Federal income tax in the amount of $1,321.05. The sole issue for decision is whether petitioners are entitled to a residential energy credit under section 44C(a)(2).
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