OPINION
GERBER, Judge:
Respondent determined a deficiency of $392,481 in petitioner's Federal income tax for the taxable year ended December 31, 1980. The issue for our consideration involves the computation of the "minimum tax." More specifically we are asked to redetermine whether petitioner may use income tax credits to reduce the amount of tax preference determined under the alternative formula (found in section 1.57-1(i)(2)(i), Income Tax Regs...
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