Memorandum Opinion
STERRETT, Judge:
By notice of deficiency dated November 16, 1979 respondent determined a deficiency of $9,785 in petitioners' Federal income tax for their taxable year ended December 31, 1976. After concessions, the sole issue for decision is whether respondent properly imposed the minimum tax under section 56(a), I.R.C. 1954, on the entire amount of petitioners' 1976 tax preference items, as determined under section 57(a)(9).
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