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and leaves, on these facts, no room for interpretation." Okin v.
Commissioner, T.C. Memo. 1985-199, affd. per curiam 808 F.2d 1338
(9th Cir. 1987). Thus, there is no justification, in the instant
case, to ignore the plain language of the statute, particularly
where, as here, "we have a complex set of statutory provisions
marked by a high degree of specificity." Huntsberry v.
Commissioner, supra at 748.
The alternative minimum tax serves to impose a tax whenever
the sum of specified percentages of the excess of alternative
minimum taxable income over the applicable exemption amount
exceeds the regular tax for the taxable year. Sec. 55(a),
(b)(1)(A), (c), (d)(1); cf. Huntsberry v. Commissioner, supra at
744. "Alternative minimum taxable income" essentially means the
taxpayer's taxable income for the taxable year determined with
the adjustments provided in section 56 and increased by the
amount of items of tax preference described in section 57.
In Huntsberry v. Commissioner, supra, we held that tax
preferences are a significant, but not necessarily an
indispensable component, of "alternative minimum taxable income".
Accordingly, the taxpayers in that case were held liable for the
alternative minimum tax computed in accordance with the specific
provisions of section 55, notwithstanding the fact that the
taxpayers did not have any items of tax preference for the
taxable year in issue. The same result applies in the present
case.
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