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Constitution (Double Jeopardy Clause) or otherwise unlawfully
penalizes petitioners twice for the same conduct. We hold that
it does not.
5. Whether respondent's determination that petitioners are
liable for the addition to tax for failure to timely file under
section 6651(a)(1) for 1991 and 1992 is invalid because
respondent unlawfully selected them for audit. We hold that it
is not.
6. Whether petitioners have made a prima facie showing
that the addition to tax under section 6651(a)(1) was selectively
applied to them by respondent. We hold that they have not.
Thus, petitioners are not entitled to discover from respondent
statistics relating to respondent’s application of the addition
to tax under section 6651(a)(1) to other taxpayers.
References to petitioner are to Patrick W. Healey.
References to petitioner wife are to Nancy L. Marshall. Section
references are to the Internal Revenue Code in effect for the
years in issue. Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners are married and lived in Lincoln, Nebraska, when
they filed the petitions in these cases.
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