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v. Commissioner, 118 T.C. 1, 5 (2002). The alternative minimum
tax 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. Sec. 55; Huntsberry v. Commissioner, 83 T.C.
742, 747-748 (1984). In Huntsberry, we held that tax preferences
are a significant, but not necessarily an indispensable
component, of alternative minimum taxable income. Thus, the
taxpayers in that case were subject to the AMT although they did
not have any tax preference items. See also Klaassen v.
Commissioner, T.C. Memo. 1998-241, affd. without published
opinion 182 F.3d 932 (10th Cir. 1999).
We are not unsympathetic to petitioners’ position. There
have been proposals of some in Congress to change the law, and
further there have been well-intended criticisms by some relating
to the unintended effects of the provisions of the AMT. In
Speltz v. Commissioner, 124 T.C. 165, 176 (2005), we stated:
The unfortunate consequences of the AMT in various
circumstances have been litigated since shortly after
the adoption of the AMT. In many different contexts,
literal application of the AMT has led to a perceived
hardship, but challenges based on equity have been
uniformly rejected. [Citations omitted.]
However unfair this statute might seem to petitioners, the
Court must apply the law as written. As this Court noted in Hays
Corp. v. Commissioner, 40 T.C. 436, 443 (1963), affd. 331 F.2d
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