- 248 - substantial understatements of their income tax liabilities for the taxable years 1982 and 1983 at a rate equal to 10 percent of the underpayment. In short, the Youngs and the DuFresnes had contested the addition to tax only insofar as their liabilities depended upon respondent's prevailing on their deficiencies to a sufficient extent to exceed the substantial understatement threshold of section 6661(b)(1)(A) (deficiency must exceed greater of 10 percent of the tax required to be shown on the return, or $5,000). See id. at 1513-1514, 1991 T.C.M. (RIA), at 91-3058. iv. Increased Interest Judge Goffe sustained respondent's determinations that the Thompsons were liable for interest computed at the increased rate prescribed in section 6621(c) for 1981, that the Youngs were liable for such increased interest for the taxable year 1982, and that the DuFresnes were liable for such increased interest for the taxable years 1982 and 1983.110 In short, Judge Goffe sustained these determinations on the ground that the Court had already determined that the test case petitioners' underpayments were attributable to "tax motivated transactions"; viz, sham transactions, as provided in section 6621(c)(3)(A)(v). See id. at 1514, 1991 T.C.M. (RIA), at 91-3058. 110 Nontest case petitioners who signed post-1985 piggyback agreements agreed to be bound by the Court’s determination in the test cases regarding the applicability of sec. 6621(c).Page: Previous 238 239 240 241 242 243 244 245 246 247 248 249 250 251 252 253 254 255 256 257 Next
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