MEMORANDUM OPINION
JACOBS, Judge:
This matter is before the Court on respondent's motion, and petitioner's cross-motion, for partial summary judgment pursuant to Rule 121. Both parties submitted memoranda in support of their positions.
Our task in connection with these motions is to determine the proper methodology to be used in calculating the amount of petitioner's "regular tax deduction" for purposes of computing its minimum tax liability under...
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