MEMORANDUM OPINION
LARO, Judge:
This case was submitted to the Court without trial under Rule 122. Respondent determined deficiencies of $1,706,000, $2,725,835, and $444,347 in petitioner's Federal income tax for 1988, 1989, and 1990, respectively. We must decide whether petitioner is entitled to investment tax credits that it claims under the transition rules contained in section 204(a)(7) of the Tax Reform Act of 1986 (TRA), Pub. L. 99-514, 100 Stat. 2146...
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