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Respondent determined a deficiency of $1,341 in petitioners’
2000 Federal income tax. The issue is whether petitioners are
liable for an alternative minimum tax. Petitioners resided in
Glenside, Pennsylvania, at the time they filed the petition.
The facts may be summarized as follows. Petitioners timely
filed their 2000 Federal income tax return reporting a total tax
liability of $32,335.55. The return showed tax payments of
$32,129.12 and a balance due of $206.43, which presumably was
remitted when the return was filed. The computation of the tax
reported included what respondent determined was a mathematical
error of $119.01 in petitioners’ favor, reducing petitioners’
total tax liability to $32,216.54. The computation of that
liability did not include the so-called alternative minimum tax
(AMT). See sec. 55. Respondent informed petitioners that they
were liable for the AMT. Petitioners filed a Form 6251,
Alternative Minimum Tax--Individuals, on which they reported (and
paid) an additional liability of $1,222. Subsequently,
respondent sent petitioners a Notice CP12, 2000 Tax Statement,
and mistakenly issued a refund check to petitioners of $1,341.01,
which is the sum of the mathematical error ($119.01) and the AMT
($1,222) amounts. In the accompanying correspondence there was
no specific identification of the erroneous items giving rise to
the refund. The statement showed that petitioners’ total tax
payments for the 2000 year were $33,557.55, which is the total of
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