OPINION
FAY, Judge:
Respondent determined a deficiency of $8,598 in petitioners' Federal income tax for 1976. The issue is whether certain foreign-source capital gain recognized by petitioners is subject to the minimum tax imposed by section 56.
All the facts have been stipulated and are found accordingly.
Petitioners Guy G. Tropeano and Gloria Tropeano resided in Weston, Mass., when they filed their petition...
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