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On the instant record, we find that petitioner may not challenge
the existence or the amount of the tax of $7,691 determined in
the 1999 notice of deficiency that respondent assessed on Febru-
ary 24, 2003.
With respect to the $21,378 increase in 1999 tax that
respondent assessed on May 5, 2003, and that is attributable to
the 1999 return, petitioner did not receive a notice of defi-
ciency and did not otherwise have an opportunity to dispute that
tax. We shall review on a de novo basis respondent’s determina-
tions with respect to such increase in 1999 tax. Sego v. Commis-
sioner, supra; Goza v. Commissioner, supra. Petitioner made
general and vague allegations in the petition about whether the
total tax for his taxable year 1999 is the amount shown as total
tax in the 1999 return. However, petitioner failed to specify
the basis for any disagreement that he may have regarding the
total tax shown in that return.8 On the instant record, we find
that petitioner has failed to show that he is not liable for the
$21,378 increase in 1999 tax that respondent assessed on May 5,
2003, and that is attributable to the 1999 return.
We turn next to the respective additions to tax under
section 6651(a)(1) and (2) that respondent assessed with respect
8Petitioner did not claim in the petition that any items of
income, deduction, or credit reported, or any computations made,
in the 1999 return were incorrect.
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