Scott William Katz - Page 7

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                    The cases before us, however, concern the construction            
               of existing statutes.  The relevant question is not whether,           
               as an abstract matter, the rule advocated by petitioners               
               accords with good policy.  The question we must consider is            
               whether the policy petitioners favor is that which Congress            
               effectuated by its enactment of �6501.  Courts are not                 
               authorized to rewrite a statute because they might deem its            
               effects susceptible of improvement.  See TVA v. Hill, 437              
               U.S. 153, 194-195 (1978).  * * *                                       
          See Rath v. Commissioner, 101 T.C. 196, 200 (1993).                         
               We have noted some circumstances in which the alternative              
          minimum tax could produce results that may be perceived as                  
          unfair.  See, e.g., Kenseth v. Commissioner, 114 T.C. 399, 407-             
          408 (2000), affd. 259 F.3d 881 (7th Cir. 2001); Klaassen v.                 
          Commissioner, 83 AFTR 2d 99-1750, 99-1 USTC par. 50,418 (10th               
          Cir. 1999), affg. T.C. Memo. 1998-241.                                      
               The Congress did give some consideration to the treatment of           
          lower-income people.  The relevant relief that the Congress chose           
          is embodied in section 55(d), which provides an exemption amount            
          of $22,500 for petitioner for 2000.6  We are not free to alter              
          this amount, or otherwise engage in “wrenching from the words of            
          * * * [the] statute a meaning which literally they did not bear”            
          (Crooks v. Harrelson, 282 U.S. at 60) in order to achieve the               
          result petitioner seeks.                                                    

               6  For 2003 and 2004, the exemption amount for a married               
          person filing separately is $29,000.  Sec. 55(d)(1)(C).  We do              
          not have authority to give even this limited relief any                     
          retroactive effect beyond what the Congress provided.  See, e.g.,           
          Sallies v. Commissioner, 83 T.C. 44, 53 n.12 (1984) (and cases              
          there cited).                                                               





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