- 8 - argue that they are being unfairly saddled with the alternative minimum tax simply because of the size of their family. The clearest expression of legislative intent is found in the actual language used by Congress in enacting legislation. As the Supreme Court has stated, "There is * * * no more persuasive evidence of the purpose of a statute than the words by which the legislature undertook to give expression to its wishes." United States v. American Trucking Associations, Inc., 310 U.S. 534, 543 (1940); see Rath v. Commissioner, 101 T.C. 196, 200 (1993) (controlling effect will generally be given to the plain language of a statute, unless to do so would produce absurd or futile results). Again as the Supreme Court has stated: in the absence of a clearly expressed legislative intention to the contrary, the language of the statute itself must ordinarily be regarded as conclusive. Unless exceptional circumstances dictate otherwise, when we find the terms of a statute unambiguous, judicial inquiry is complete. [Burlington N. R.R. Co. v. Oklahoma Tax Commn., 481 U.S. 454, 461 (1987); citations and internal quotation marks omitted.] Accordingly, where, as here, a statute appears to be clear on its face, unequivocal evidence of a contrary purpose must be demonstrable if we are to construe the statute so as to override the plain meaning of the words used therein. Estate of Owen v. Commissioner, 104 T.C. 498, 507-508 (1995), and cases cited therein; Huntsberry v. Commissioner, 83 T.C. 742, 747-748 (1984). "The statutory scheme governing the imposition and computation of the alternative minimum tax is clear and precise,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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