NEWMAN, Circuit Judge.
The appellants are nineteen individual taxpayers who were partners of the Denver-based Dillon Oil Technology Partnership in tax years 1983 and 1984. In 2003, after over a decade of litigation, the IRS assessed penalties in accordance with now repealed I.R.C. § 6621(c), which penalizes "substantial" underpayments of tax "attributable to tax motivated transactions" ("TMTs"). The appellants paid the tax and penalties in 2004, and, in 2006...
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