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respondent asserts that the filing of the lien is the event that
triggered petitioner’s right to a section 6330 hearing and
subsequently to our review of respondent’s determination to
continue collection activities, as well as the denial of
petitioner’s request for the abatement of interest and additions
to tax. We agree with this assertion.
We now turn to whether respondent’s denial of petitioner’s
request for the abatement of additions to tax was an abuse of
discretion. Both parties acknowledge that this Court has
jurisdiction in this section 6330(d) proceeding to consider
whether respondents’s refusal to abate the additions to tax
relating to petitioner’s income tax liabilities was an abuse of
discretion. See Montgomery v. Commissioner, 122 T.C. 1 (2004);
Downing v. Commissioner, 118 T.C. 22 (2002).
The income tax assessments for the years in question include
assessments for additions to tax under section 6651(a)(1) and (2)
for 1996-99 and under section 6654 for 1996-97. Petitioner did
not have an opportunity to dispute these additions; hence, he can
challenge them during the section 6330 hearing proceeding. Sec.
6330(c)(2)(B). We review de novo respondent’s determination with
respect to these additions to tax. See Goza v. Commissioner, 114
T.C. 176, 181-182 (2000).
Section 6651(a)(1) imposes an addition to tax for failure to
timely file a return, and section 6651(a)(2) imposes an addition
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