- 13 - 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...)Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007