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" ... Judge Nega could have left it at that, but he went into some detail on the insubstantiality of the compliance. The IRS had conceded on the penalty for 2015. Judge Nega upheld the 20% penalty for 2012 and 2013. Mr. Chiarelli argued that he relied on Mr. Durante on the appraisal matters, but Judge Nega held him to a higher standard, him being a tax attorney qualified to practice in the Tax Court. ... "