Charles C. Allen, III and Barbara N. Allen, et al. - Page 9




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          Petitioners assert that the wage-expense limitation is not                    
          applicable to the AMTI calculation under a plain reading of                   
          section 280C(a) because a TJC is never determined in the AMT                  
          regime.  Respondent acknowledges that the primary reading of the              
          provisions underlying the AMT regime requires that a taxpayer                 
          calculate AMTI by adjusting taxable income in the manner set                  
          forth in section 55(b) but invites the Court to adopt the                     
          alternative reading advanced by petitioners under which the AMT               
          and regular tax regimes are considered parallel systems in that               
          the computation of AMT starts from scratch without regard to any              
          calculation made for regular tax purposes.  Respondent argues                 
          that the fact that a TJC is determined for the regular tax regime             
          is enough to subject petitioners to the wage-expense limitation               
          in the calculation of AMTI under the AMT regime given the absence             
          of any statutory provision that provides to the contrary.                     
               We agree with respondent that the wage-expense limitation of             
          section 280C(a) enters into the calculation of AMTI but do so for             
          reasons different than he espouses.  Our analysis begins with the             
          relevant statutory text.  We interpret that text with reference               
          to the legislative history primarily to learn the purpose of the              
          statute and to resolve any ambiguity in the words contained in                
          the text.  Landgraf v. USI Film Prods., 511 U.S. 244 (1994);                  
          Commissioner v. Soliman, 506 U.S. 168, 174 (1993); Consumer Prod.             
          Safety Commn. v. GTE Sylvania, Inc., 447 U.S. 102, 108 (1980);                






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