Dimitrios T. Manousos and Anne M. Manousos - Page 4




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          $2,636.  The deficiency was attributable solely to the                      
          alternative minimum tax (AMT).3                                             
               Respondent mailed a notice of deficiency to Mr. Manousos and           
          a duplicate original to Mrs. Manousos.  Both documents were sent            
          by certified mail, and each was mailed to petitioners’ Joplin               
          Lane address in Virginia Beach, Virginia.  That address was at              
          the time, and has remained through the present day, petitioners’            
          mailing address.                                                            
               Petitioners did not contest respondent’s deficiency                    
          determination by filing a petition for redetermination with this            
          Court.  See sec. 6213(a).  Accordingly, upon petitioners’                   
          default, respondent assessed the deficiency, together with                  
          statutory interest, on December 6, 2004.  On that same date,                
          respondent sent petitioners a statutory notice of balance due,              
          i.e., notice and demand for payment.  See sec. 6303(a).                     
          Petitioners did not pay the full amount due.                                
          Final Notice of Intent To Levy                                              
               On March 18, 2006, respondent sent to petitioners a Final              
          Notice/Notice of Intent to Levy and Notice of Your Right to a               
          Hearing (final notice).  See sec. 6330(a).  Respondent sent the             


               3  In computing the AMT, no deduction is allowed for various           
          deductions, specifically including:  (1) State and local taxes              
          otherwise deductible on a Schedule A; (2) itemized miscellaneous            
          deductions; and (3) exemptions.  See sec. 56(b)(1).  Therefore,             
          for AMT purposes, petitioners were deprived of deductions worth             
          $37,644 that were otherwise allowable under the “regular”, i.e.,            
          sec. 1, income tax.                                                         





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