Willmus for Benefit of Willmus v. COM'N OF REV.

OPINION

WAHL, Justice.

The taxpayer-relators in this case appeal by certiorari a decision of the Tax Court affirming orders by the Commissioner of Revenue assessing 1979 Minnesota minimum tax on their capital gain deductions, pursuant to Minn.Stat. § 290.091 (Supp. 1979). We affirm.

Minn.Stat. § 290.091 (Supp.1979), the provision governing liability for state minimum tax on capital gains deductions, measures that liability as a percentage of the taxpayers’ federal liability for preference items, including capital gain deductions, under analogous provisions of the Internal Revenue Code…