Justice Souter, delivered the opinion of the Court.
Under §§ 56 and 57(a)(8) of the Internal Revenue Code of 1954, 26 U. S. C. §§ 56, 57(a)(8) (1976 ed.), a taxpayer must pay a "minimum tax" on the excess of the allowable depletion deduction for an interest in a mineral deposit over the taxpayer's adjusted basis for that interest. The question presented here is whether the term "adjusted basis," as used in § 57(a)(8), includes certain depreciable...
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