OPINION
STERRETT, Chief Judge:
By notice of deficiency dated December 18, 1985, respondent determined deficiencies in petitioner's Federal income taxes for the calendar years 1976 and 1977 in the amounts of $33,074 and $65,944, respectively. The deficiencies result from respondent's disallowance of an investment credit that petitioner claimed in 1979 and carried back to 1976 and 1977. Due to concessions by petitioner...
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