POLITZ, Circuit Judge:
This appeal poses the question whether the minimum tax imposed on individual tax preference items under former IRC § 56, 26 U.S.C. § 56 (now IRC § 55, 26 U.S.C. § 55), is subject to the income averaging provision of IRC §§ 1301-05, 26 U.S.C. §§ 1301-05. The Commissioner determined that the averaging provisions did not apply; the Tax Court agreed. We affirm.
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