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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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