OPINION
RAUM, Judge:
The Commissioner determined a deficiency in petitioners' 1982 income tax in the amount of $48,081. The sole issue for decision is whether petitioners are entitled to a credit under section 38, I.R.C. 1954, in the amount allowed by section 46(a)(2)(F) with respect to property qualifying under section 48(g) as a rehabilitated building. Resolution of this issue requires a determination of...
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