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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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