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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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Last modified: November 10, 2007