George A. and Marysue Coward - Page 2

                                                   2                                                     
                 Additions to Tax            Additional Interest                                         
     Sec.      Sec.       Sec.        Sec.           Sec.                                                
     Year  Deficiency  6653(a)  6653(a)(1) 6653(a)(2)    6659          6621(c)                           
     1975    $ 4,847     $242       --        --           --                                            
     1976      4,946      247       --        --           --                                            
     1977      6,576      329       --        --           --                                            
     1978      7,231      362       --        --           --                                            
     1979      6,789      339       --        --           --                                            
     1980     11,655      583       --        --           --                                            
     1981     13,081       --      $654        1        $3,924                                           
     1982      9,751       --       488        1         2,925                                           
     1  50 percent of the interest due to the underpayment of tax attributable to negligence or          
     intentional disregard of rules and regulations.                                                     
     2  120 percent of the interest due with respect to any substantial underpayment attributable to     
     tax motivated transactions.                                                                         

                  After concessions reflected in the Stipulation of Settled                              
            Issues, filed March 24, 1995,2 the issue for decision is whether                             
            petitioners are entitled to an investment tax credit for the                                 
            taxable year 1978, and, if so, in what amount, and whether they                              
            are entitled to any related carrybacks.  This case was submitted                             
            fully stipulated pursuant to Rule 122.  The stipulation of facts                             
            and the attached exhibits are incorporated herein by this                                    
            reference.  Petitioners resided in Fair Oaks, California, at the                             


            2     In their Stipulation of Settled Issues, the parties                                    
            stipulated that, exclusive of the investment tax credit issue,                               
            there are deficiencies in petitioners' Federal income taxes as                               
            follows:                                                                                     
            Taxable Year      Deficiency                                                                 
            1975            $4,847                                                                       
            1976             4,946                                                                       
            1977             6,727                                                                       
            1978             1,495                                                                       
            1979             1,549                                                                       
            1980             9,043                                                                       
            1981             8,750                                                                       
            1982             3,468                                                                       
                  The parties further stipulated that there are no additions to tax under                
            secs. 6653(a), 6653(a)(1), 6653(a)(2), and 6659 for any of the years in issue,               
            and that no part of the deficiencies is a substantial underpayment for the                   
            purposes of computing interest payable with respect to such amounts pursuant                 
            to sec. 6621(c) (formerly sec. 6621(d)).                                                     




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