LAY, Chief Judge.
James E. Rhude is a shareholder in Rhude & Fryberger, Inc., a mining corporation located in northern Minnesota. The corporation has elected subchapter S status; taxpayers now challenge their liability on their 1973 joint return for the minimum tax, see 26 U.S.C. § 56 (1970), on a tax preference item consisting of their share of a $97,487 percentage depletion deduction, see 26 U.S.C. §§ 611, 613 (1970), taken by Rhude...
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