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other court, and this opinion shall not be treated as precedent
for any other case.
This matter is before the Court on respondent’s Motion For
Summary Judgment, as supplemented. In his motion, respondent
moves for a summary adjudication in his favor in this collection
review case involving a proposed levy for 2002. For reasons
discussed hereinafter, we shall grant respondent’s motion.
Background
At the time that the petition was filed, petitioner
Dimitrios T. Manousos (Mr. Manousos) and petitioner Anne M.
Manousos (Mrs. Manousos) resided in Virginia Beach, Virginia. We
shall refer to Mr. and Mrs. Manousos collectively as petitioners.
Petitioners’ Income Tax Liability for 2002
Petitioners timely filed a Federal income tax return for
2002. On their return, petitioners reported a tax liability,
which they paid in full through a combination of withholding and
a remittance enclosed with their return.2
Subsequently, respondent examined petitioners’ return. By
notice dated July 29, 2004, respondent determined a deficiency of
2 On their return, petitioners claimed five exemptions
($15,000) and itemized their deductions on Schedule A, Itemized
Deductions. Included among those deductions were State and local
taxes in the amount of $5,570 and various miscellaneous
deductions in the net amount of $17,074. See sec. 67, imposing a
2-percent floor on miscellaneous itemized deductions.
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