James A. and Nancy B. Wiese - Page 10

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          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.                                                    






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