Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
The Commissioner determined a deficiency in petitioners' 1981 Federal income tax of $57,818.70. We must decide whether petitioners' sale of stock required a recapture of investment tax credit pursuant to section 47(a)(1).
Some of the facts have been stipulated and are so found. Petitioners are husband and wife and resided in Bryant, Arkansas at the time the petition...
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