Chabot, J., concurring: Section 6651(a)(2) was added to the Code by section 943(a) of the Tax Reform Act of 1969 ( Pub. L. 91-172, 83 Stat. 487, 727). The legislative history of the 1969 Act does not indicate that the Congress considered the question of whether an addition to the tax under section 6651(a)(2) is to be subject to redetermination by this Court. As is ap…
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