OPINION
COHEN, Judge:
Respondent determined a deficiency of $1,999 in petitioner's Federal income tax for 2001 that was attributable to respondent's disallowance of depreciation deductions and tax credits claimed by petitioner with respect to two public pay telephones (pay phones). In an amendment to answer, respondent asserted an increased deficiency of $30,247 and a penalty of $6,049 under section 6662...
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