- 27 -
parallel to their treatment for regular tax purposes does not, in
our minds, mean that the entire AMT regime runs parallel to the
regular tax regime.12
Although the legislative history to a statute is secondary
when the Court can apply the plain meaning of unambiguous
statutory text, we recognize that unequivocal evidence of a clear
legislative intent may sometimes override a plain meaning
interpretation and lead to a different result. Consumer Prod.
Safety Commn. v. GTE Sylvania, Inc., 447 U.S. 102, 108 (1980);
see also Halpern v. Commissioner, 96 T.C. 895, 899 (1991);
Hirasuna v. Commissioner, 89 T.C. 1216, 1224 (1987); Huntsberry
v. Commissioner, 83 T.C. 742, 747-748 (1984). Here, the
legislative history of the statutes provides scant and
unpersuasive support for a holding contrary to that which we
reach herein.
As to section 280C(a), its genesis lies in the Tax Reduction
and Simplification Act of 1977 (1977 Act), Pub. L. 95-30,
91 Stat. 126, which also is the statute that spawned the new jobs
credit of former sections 44B, 51, 52, and 53. Given the
presence at that time of high marginal tax rates and the
12 Nor are we persuaded by the preamble or technical advice
memorandum upon which petitioners rely. In addition to the
obvious fact that these documents also are not items of
legislative history, these documents are afforded little weight
in this Court. Textron Inc. v. Commissioner, 115 T.C. 104, 110
(2000) (technical advice memorandum); Dobin v. Commissioner,
73 T.C. 1121, 1129 n.9 (1980) (preamble to proposed regulations).
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