- 7 -
6654(d). During the 5 years in issue, petitioner received income
totaling $412,221. His tax liability totaled $137,175, yet his
tax payments totaled zero. Petitioner offered no evidence
showing that he qualified under an exception to section 6654(a).
Accordingly, we hold that petitioner is liable for additions to
tax under section 6654(a).
Finally, we consider whether a penalty should be imposed
under section 6673. Section 6673(a)(1) provides that, whenever
it appears to the Tax Court that the taxpayer's position in a
proceeding is frivolous or groundless, the Court may impose a
penalty not in excess of $25,000. This Court has often imposed
such penalties on taxpayers who make frivolous tax protester
arguments. See, e.g., Coulter v. Commissioner, 82 T.C. 580, 584-
586 (1984); Abrams v. Commissioner, 82 T.C. 403, 408-413 (1984);
Wilkinson v. Commissioner, 71 T.C. 633, 639-643 (1979);
Santangelo v. Commissioner, T.C. Memo. 1995-468; McNeel v.
Commissioner, T.C. Memo. 1995-211; Devon v. Commissioner, T.C.
Memo. 1995-206; Carr v. Commissioner, T.C. Memo. 1995-138; cf.
Connor v. Commissioner, 770 F.2d 17, 20 (2d Cir. 1985) (noting
that the argument that wages are not income "has been rejected so
frequently that the very raising of it justifies the imposition
of sanctions").
In this case, petitioner knew that courts have repeatedly
rejected his constitutional arguments and repeatedly imposed the
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