OPINION
SWIFT, Judge:
Respondent determined deficiencies in petitioners' consolidated Federal income tax for their taxable year ending June 30, 1979, in the amount of $82,587. Respondent also disallowed various investment tax credits claimed on petitioners' consolidated Federal income tax return for their taxable year ending June 30, 1980, in the amount of $394,288, which credits were claimed as carryback credits to petitioners' 1979 taxable year...
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