- 12 -
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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