Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $70,138 in petitioners' Federal income taxes for 1985. The deficiency is based upon respondent's disallowance of depreciation deductions, the investment tax credit, and the business energy credit.
The sole issue for decision is whether certain photovoltaic (solar energy) system equipment was placed in service during 1985 within the meaning of sections 38,...
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