Memorandum Opinion
SIMPSON, Judge:
This matter is before the Court on the Commissioner's motion for judgment on the pleadings. The issue for decision is whether the provision of the Tax Reform Act of 1976 making the new base and rate for the application of the minimum tax provisions retroactive to taxable years beginning after December 31, 1975, is constitutional. The parties presented oral arguments on the Commissioner's motion and filed briefs in support...
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