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applicable exemption amount of $49,000 by $24,196. See sec.
55(d)(1)(A)(i). Petitioners’ “tentative minimum tax” is
therefore 26 percent of the taxable excess; i.e., 26 percent of
$24,196, or $6,291. See sec. 55(b)(1)(A)(i)(I). Because the
tentative minimum tax exceeds the regular tax of $963,
petitioners are liable for the AMT in the amount of such excess,
i.e., $6,291 less $963, or $5,328. See sec. 55(a).
Petitioners do not challenge the mechanics of the foregoing
computation. Rather, as previously stated, petitioners contend
that the AMT should not apply to them under the circumstances of
their case, and they ask for a waiver from such tax on equitable
grounds, including the fact that they had no items of tax
preference.
The clearest expression of legislative intent is found in
the actual language used by Congress in enacting legislation. As
the Supreme Court stated: “There is * * * no more persuasive
evidence of the purpose of a statute than the words by which the
legislature undertook to give expression to its wishes.” United
States v. Am. Trucking Associations, Inc., 310 U.S. 534, 543
(1940); see Rath v. Commissioner, 101 T.C. 196, 200 (1993)
(controlling effect will generally be given to the plain language
of a statute, unless to do so would produce absurd or futile
results). Again, as the Supreme Court stated: “In the absence
of a clearly expressed legislative intention to the contrary, the
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