David R. and Margaret J. Klaassen - Page 12

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          religious belief, is a compelling governmental interest"); see              
          also Bob Jones Univ. v. United States, 461 U.S. 574, 603 (1983).            
               In the present case, the alternative minimum tax is not                
          based upon "a classification grounded on religion."  Rather, the            
          statute demonstrates that such tax is triggered by the value of             
          deductions and exemptions claimed, the disallowance of which is             
          unrelated to a taxpayer's religious beliefs.  Cf. Commissioner v.           
          Sullivan, 356 U.S. 27, 28 (1958); New Colonial Ice Co. v.                   
          Helvering, 292 U.S. 435, 440 (1934) (deductions are a matter of             
          legislative grace; accordingly, the decision whether to permit              
          particular deductions and under what circumstances lies within              
          the discretion of Congress).  Consequently, we do not agree that            
          the alternative minimum tax unconstitutionally inhibits the free            
          exercise of petitioners' religion.                                          
          C. Conclusion                                                               
               In view of the foregoing, we hold that petitioners are                 
          liable for the alternative minimum tax.  Accordingly, we sustain            
          respondent's determination of the deficiency in income tax.                 
               Absent some constitutional defect, we are constrained to               
          apply the law as written, see Estate of Cowser v. Commissioner,             
          736 F.2d 1168, 1171-1174 (7th Cir. 1984), affg. 80 T.C. 783, 787-           
          788 (1983), and we may not rewrite the law because we may deem              
          its effects susceptible of improvement; see Commissioner v.                 
          Lundy, 516 U.S. 235, 252 (1996), (quoting Badaracco v.                      
          Commissioner, 464 U.S. 386, 398 (1984)).   Accordingly,                     




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