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when computing AMT, because section 56(b)(1)(F) provides that the
section 68 limitation does not apply when determining the amount
of AMTI. However, petitioner’s argument is based on his narrow
interpretation of the Code. Further, petitioner misunderstands
the application of section 56(b)(1)(F) and the operation of
section 56(b) as a whole.
When interpreting statutes, the function of courts is to
construe the language of the statute to give effect to the intent
of Congress. Cramer v. Commissioner, 101 T.C. 225, 247 (1993),
affd. 64 F.3d 1406 (9th Cir. 1995). Where possible, the words of
the statutes should be interpreted in their ordinary everyday
sense. Crane v. Commissioner, 331 U.S. 1, 6 (1947). A statute
is to be construed so as to give each of its provisions full
effect and not to render parts of the statute inoperative or
superfluous. Duke v. Univ. of Tex., 663 F.2d 522, 526 (5th Cir.
1981).
Accordingly, section 56(b) should be read in its entirety,
as part of a single statutory scheme, and not so as to render
part of the statute inoperative. Section 56(b), in pertinent
part, provides as follows:
SEC. 56(b). Adjustments Applicable to Individuals.–-
In determining the amount of the alternative minimum
taxable income of any taxpayer (other than a
corporation), the following treatment shall apply (in
lieu of the treatment applicable for purposes of
computing the regular tax):
(1) Limitation on deductions.--
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