OPINION
RAUM, Judge:
The Commissioner determined a $1,591.30 deficiency in petitioners' 1983 income tax. Petitioners, husband and wife, filed a joint return as well as two successive amended joint returns. The deficiency resulted in part from the disallowance of an investment tax credit (ITC) claimed by petitioners in their first amended return, and they now seek a determination of an overpayment of $10,639. After certain concessions, the only issue...
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