David R. and Margaret J. Klaassen - Page 7

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          applicable exemption amount of $45,000 by $23,832.44.  See sec.             
          55(d)(1)(A)(i).  Petitioners' "tentative minimum tax" is                    
          therefore 26 percent of that excess, or $6,196.43.  See sec.                
          55(b)(1)(A)(i)(I).  Because petitioners' tentative minimum tax              
          exceeds petitioners' regular tax of $5,111, petitioners are                 
          liable for the alternative minimum tax in the amount of such                
          excess; i.e., $6,196.43 less $5,111, or $1,085.43.                          
               Petitioners do not challenge the mechanics of the foregoing            
          computation.  Rather, petitioners contend that they are not                 
          liable for the alternative minimum tax for two independent                  
          reasons.  First, petitioners contend that the elimination of                
          personal exemptions under the alternative minimum tax adversely             
          affects large families and results in an application of the                 
          alternative minimum tax that is contrary to congressional intent.           
          In this regard, petitioners argue that legislative history                  
          demonstrates that the alternative minimum tax was intended to               
          limit items of tax preference, not personal exemptions.                     
               Second, petitioners argue that the alternative minimum tax             
          violates various constitutional rights, particularly the right to           
          religious freedom.                                                          
          A. Congressional Intent                                                     
               We begin with petitioners' contention that they are not                
          liable for the alternative minimum tax because such tax was not             
          intended to apply to them.  In this regard, petitioners emphasize           
          that they did not have a single item of tax preference, and they            




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