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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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