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If Congress had intended to tax only tax preferences, it
would have defined "alternative minimum taxable income"
differently, for example, solely by reference to items of tax
preference. Instead, Congress provided for a tax measured by a
broader base, namely, alternative minimum taxable income, in
which tax preferences are merely included as potential
components.
The foregoing analysis leads to the conclusion that the
alternative minimum tax is triggered by a number of factors,
including the value of personal exemptions claimed on a
taxpayer's return, and that respondent correctly determined such
tax on the facts of this case. Accordingly, because we can
understand and apply the plain meaning of unambiguous statutory
text, we need not defer to legislative history. See Calvert
Anesthesia Associates v. Commissioner, 110 T.C. 285, 289 (1998);
see also Huntsberry v. Commissioner, supra at 745-746 ("there is
no solid basis in the legislative history or otherwise for
refusing to apply section 55 as written").
B. Constitutional Considerations
Having thus decided that the alternative minimum tax is
otherwise applicable on the facts of this case, we turn now to
petitioners' contention that such tax unconstitutionally inhibits
the free exercise of religion.
Cases have held that the usual presumption of
constitutionality is particularly strong in the case of a revenue
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