Mark S. & Lois A. Freme - Page 14




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          each of their taxable years 1999 through 2003.  Petitioners thus            
          dispute the amount of the unpaid liability for each of those                
          years.  We shall review that dispute on a de novo basis.  Sego v.           
          Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114           
          T.C. 176, 181-182 (2000).                                                   
               Although petitioners allege in the petition that respondent            
          did not account for all of the payments that they made with                 
          respect to each of their taxable years 1999 through 2003, they do           
          not identify any such payments.  On the instant record, we are              
          unable to find that respondent failed to account for all of the             
          payments that petitioners made for each of those years.                     
               As we understand it, petitioners advance as an alternative             
          argument that they should be relieved from paying any addition to           
          tax and interest with respect to each of their taxable years 1999           
          through 2003.  We construe that argument as a request to review             
          respondent’s failure to abate additions to tax and interest under           
          section 6404.                                                               
               We turn first to petitioners’ argument regarding respon-               
          dent’s failure to abate additions to tax under section 6404.  The           
          record does not establish that petitioners advanced that argument           
          at the Appeals Office.  Consequently, we shall not consider that            
          matter.3  Sec. 301.6320-1(f)(2), Q&A-F5, Proced. & Admin. Regs.;            

               3Assuming arguendo that the record before us established               
          that petitioners raised with the Appeals Office respondent’s                
                                                             (continued...)           





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