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issues with the Court, he has offered no evidence to indicate
that respondent incorrectly determined his AMT liability. In
addition, the Government is not prohibited from issuing a notice
of deficiency where it previously adjusted a taxpayer’s return
based on mathematical or clerical errors. See sec. 6213(b)(1);
Heasley v. Commissioner, 45 T.C. 448, 457 (1966); Ciciora v.
Commissioner, T.C. Memo. 2003-202.
Finally, we note that in his pretrial memorandum, petitioner
argues that we should reverse respondent’s determination because
“the enforcement of the [AMT] results in inequities”. He also
contends that Congress soon will enact legislation to repeal the
AMT, thereby rendering the issue in his case moot. These
arguments are also challenges to petitioner’s underlying tax
liability. Furthermore, we have rejected challenges to the AMT
based on equitable considerations, holding that such “policy
issues are in the province of Congress, and we are not authorized
to rewrite the statute.” Kenseth v. Commissioner, 114 T.C. 399,
407-408 (2000) (and cases cited therein); see also Anthes v.
Commissioner, 81 T.C. 1, 7 (1983), affd. without published
opinion 740 F.2d 953 (1st Cir. 1984) (“We must apply the law as
in effect during the taxable year in issue.”).
Based on our review of the record, we conclude that
respondent satisfied the requirements of section 6330 and did not
abuse his discretion in sustaining the proposed collection action
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