OPINION
RAUM, Judge:
The Commissioner determined an $11,117 income tax deficiency for 1984 against petitioners, husband and wife. The deficiency is attributable entirely to the alternative minimum tax. At issue is whether the capital gain deduction in this case is a tax preference where, as here, it is based upon the capital gain portion of the lump-sum distribution received by the husband from his employer upon retirement, and, if it is held to be...
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