Jerry and Patricia A. Dixon, et al - Page 173




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          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).                     

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