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have any AMT adjustments or tax preference items. Petitioners
further stated in the April 3, 2004 letter that respondent issued
a full refund because “the IRS would have never given a full
refund, if our supported items and documentation was [sic] not
excepted [sic].”
Respondent sent petitioners a letter dated June 23, 2004,
confirming proposed adjustments for the AMT.
Petitioners responded by letter dated July 3, 2004, again
stating that they were not liable for the AMT.
On August 16, 2004, respondent issued a notice of deficiency
to petitioners. In the notice of deficiency, respondent did not
disallow any of the deductions or exemptions claimed by
petitioners on their return for purposes of the income tax
imposed by section 3(a). See secs. 1(a)(1), 3(c). Respondent,
however, determined that petitioners are liable for the AMT under
section 55 in the amount of $2,747 as follows:
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