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6. Additions to Tax
i. Negligence
Judge Goffe sustained respondent's determinations that the
test case petitioners were liable for additions to tax for
negligence. In particular, Judge Goffe found that the test case
petitioners failed to show that they were unsophisticated
taxpayers, that they relied upon independent return preparers or
tax advisers, the nature of any professional advice that they may
have received, or that any such professional advice was based
upon a disclosure of all of the relevant facts. See id. at 1512-
1513, 1991 T.C.M. (RIA), at 91-3056 to 91-3057.108
ii. Late Filing
Judge Goffe sustained respondent's determination that the
Thompsons were liable for the addition to tax for late filing
under section 6651(a)(1) for 1981 on the ground that they did not
contest the matter and were deemed to have conceded the point.109
See id. at 1513, 1991 T.C.M. (RIA), at 91-3057.
iii. Substantial Understatement
Judge Goffe sustained respondent's determination that the
Youngs and the DuFresnes were liable for additions to tax for
108 Although Judge Goffe sustained respondent's
determinations that the test case petitioners were liable for
additions to tax for negligence, nontest case petitioners who
signed post-1985 piggyback agreements were to be relieved of
liability for such additions to tax for tax years before 1982.
See supra pp. 43-45.
109 We note that the Thompsons had no need to contest this
addition to tax by virtue of their settlement agreement.
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