Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency of $3,233 in the petitioners' Federal income tax for their taxable year 1976. The issues for our determination are:
(1) whether it is inequitable to hold petitioners liable for a minimum tax arising from the sale of their farm at long-term capital gain rates; and
(2) whether the minimum tax should be applied to petitioners in view of the Congressional...
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