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55(d)(1)(C). This operation resulted in petitioner’s “taxable
excess” being $16,207. Sec. 55(b)(1)(A)(ii). To this amount
respondent applied a 26-percent tax rate. Sec.
55(b)(1)(A)(i)(I). This operation resulted in petitioner’s
tentative minimum tax being $4,214, which, as we noted supra,
becomes petitioner’s alternative minimum tax.
In its unanimous opinion in Crooks v. Harrelson, 282 U.S.
55, 60 (1930), the Supreme Court gave us the following advice as
to tax statutes:
Courts have sometimes exercised a high degree of
ingenuity in the effort to find justification for wrenching
from the words of a statute a meaning which literally they
did not bear in order to escape consequences thought to be
absurd or to entail great hardship. But an application of
the principle so nearly approaches the boundary between the
exercise of the judicial power and that of the legislative
power as to call rather for great caution and circumspection
in order to avoid usurpation of the latter. Monson v.
Chester, 22 Pick. 385, 387. It is not enough merely that
hard and objectionable or absurd consequences, which
probably were not within the contemplation of the framers,
are produced by an act of legislation. Laws enacted with
good intention, when put to the test, frequently, and to the
surprise of the law maker himself, turn out to be
mischievous, absurd, or otherwise objectionable. But in
such case the remedy lies with the law making authority, and
not with the courts. See In re Alma Spinning Company, L.R.
16 Ch. Div. 681, 686; King v. Commissioner, 5 A. & E. 804,
816; Abley v. Dale, L.J. (1851) N.S. Pt. 2, Vol. 20, 233,
235. And see generally Chung Fook v. White, 264 U.S. 443,
445; Commr. of Immigration v. Gottlieb, 265 U.S. 310, 313.
More recently, the Supreme Court’s almost-unanimous opinion
in Badaracco v. Commissioner, 464 U.S. 386, 398 (1984), told us
the following about tax statutes:
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