Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined a deficiency in the amount of $327.67 in petitioners' income tax for 1976. Section 301 of the Tax Reform Act of 1976 reduced the amount of the exemption applicable to the minimum tax on tax preference items from $30,000 to $10,000, effective for taxable years beginning after December 31, 1975. The issue is whether under the due process clause of the Fifth Amendment to the Constitution...
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