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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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