Memorandum Findings of Fact and Opinion
RUWE, Judge:
Respondent determined a deficiency in petitioner's 1984 Federal income tax of $38,944.54. After concessions by the parties, the issues for decision are: (1) Whether petitioner is entitled to investment tax credit in 1984 with respect to tractors and trailers purchased in 1984; and (2) whether petitioner is entitled to section 168
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