- 9 - language of the statute itself must ordinarily be regarded as conclusive.” Burlington N. R.R. Co. v. Okla. Tax Commn., 481 U.S. 454, 461 (1987) (citations and internal quotation marks omitted). In other words, if the terms of a statute are unambiguous, then, in general, “‘judicial inquiry is complete.’” Id. (quoting Rubin v. United States, 449 U.S. 424 (1981)). “The statutory scheme governing the imposition and computation of the alternative minimum tax is clear and precise, and leaves, on these facts, no room for interpretation.” Okin v. Commissioner, T.C. Memo. 1985-199, affd. per curiam 808 F.2d 1338 (9th Cir. 1987). Thus, there is no justification, in the instant case, to ignore the plain language of the statute, particularly where, as here, “we have a complex set of statutory provisions marked by a high degree of specificity.” Huntsberry v. Commissioner, 83 T.C. 742, 748 (1984). The AMT serves to impose a tax whenever the sum of specified percentages of the excess of alternative minimum taxable income over the applicable exemption amount exceeds the regular tax for the taxable year. See sec. 55(a), (b)(1)(A), (c), (d)(1)(A); cf. Huntsberry v. Commissioner, supra at 744. “Alternative minimum taxable income” essentially means the taxpayer’s taxable income for the taxable year determined with the adjustments provided in section 56 and increased by the amount of items of tax preference described in section 57.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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