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to petitioner’s taxable year 1999.9 With respect to the addi-
tions to tax under section 6651(a)(1) and (2) of $1,036.57 and
$806.22, respectively, determined in the 1999 notice of defi-
ciency that respondent assessed on February 24, 2003, as dis-
cussed above, petitioner received the 1999 notice of deficiency
in which respondent, inter alia, determined such additions to
tax, but he did not file a petition with respect to that notice.
On the instant record, we find that petitioner may not challenge
the existence or the amount of the additions to tax under section
6651(a)(1) and (2) of $1,036.57 and $806.22, respectively,
determined in the 1999 notice of deficiency that respondent
assessed on February 24, 2003.
With respect to the increases in the 1999 additions to tax
under section 6651(a)(1) and (2) of $4,351.06 and $3,743.33,
respectively, that respondent assessed on May 5, 2003, and that
are attributable to the 1999 return, petitioner did not receive a
9Petitioner does not dispute respondent’s determination that
respondent may proceed to collect any unpaid addition to tax
under sec. 6654 for his taxable year 1999 determined in the 1999
notice of deficiency that respondent assessed on Feb. 24, 2003.
With respect to the respective additions to tax under sec.
6651(a)(1) and (2) that respondent assessed for petitioner’s
taxable year 1999, petitioner alleges in the petition that he
seeks “abatement” of those additions to tax. We construe that
allegation as a request to review (1) whether petitioner is
liable for the respective additions to tax under sec. 6651(a)(1)
and (2) that respondent assessed for his taxable year 1999 and
(2) whether, if the Court were to find that he is so liable,
respondent may proceed to collect such additions to tax.
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