- 3 - $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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007