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55(d)(1)(C)(i). Petitioner’s “tentative minimum tax” is
therefore 26 percent of the excess, or $3,601. Sec.
55(b)(1)(A)(i)(I), (iii). Because petitioner’s tentative minimum
tax exceeds the regular tax of $619, petitioner is liable for the
alternative minimum tax in the amount of such excess; i.e.,
$3,601 less $619, or $2,982. See sec. 55(a).
Petitioner does not challenge the mechanics of the foregoing
computation. Rather, petitioner contends that the alternative
minimum tax was not meant to apply to him because he is not
wealthy and had no items of tax preference.
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.]
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