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under section 6652 (a) and (c) for 1990 because they
underreported their income, overstated their deductions, and
failed to keep adequate records. See par. C, p. 15. Also, the
additions for tax for negligence and late filing are remedial.
We conclude that the Double Jeopardy Clause does not shield
petitioners from liability for additions to tax under sections
6651(a) and 6662(a).
Petitioners also contend that respondent unlawfully (other
than in violation of the Double Jeopardy Clause) penalized them
twice for the same conduct. Petitioners have not given any
authority to support this theory, and we are aware of none.
3. Imposition of the Addition to Tax Under Section
6651(a)(2)
Respondent determined that petitioners are liable for the
additions to tax under section 6651(a)(1) for all of the years in
issue but did not determine that petitioners are liable under
section 6651(a)(2). Before respondent determined that
petitioners were liable for the addition to tax under section
6651(a)(1), respondent issued a Request for Payment for 1990 to
petitioners to pay the addition to tax under section 6651(a)(2).
The Commissioner may assess tax without issuing a notice of
deficiency if a taxpayer does not pay the amount shown on his or
her return. Sec. 6213(b)(1). Petitioners paid the addition to
tax for late payment under section 6651(a)(2) before respondent
determined that they are liable for the addition to tax under
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