7
for each of the years in issue. The addition to tax is mandatory
in the absence of specified exemptions, Grosshandler v.
Commissioner, 75 T.C. 1 (1980), and petitioners have not shown
that any of the exemptions apply to them.
We turn now to respondent's request that a penalty against
petitioners under section 6673(a) be awarded. As relevant
herein, section 6673(a)(1) authorizes the Tax Court to require a
taxpayer to pay to the United States not in excess of $25,000
whenever it appears that proceedings have been instituted or
maintained by the taxpayer primarily for delay or that the
taxpayer's position in such proceeding is frivolous or
groundless.
The record in this case convinces us that petitioners were
not interested in disputing the merits of either the deficiencies
in income tax or the additions to tax determined by respondent in
the notice of deficiency. Rather, the record demonstrates that
petitioners regarded this case as a vehicle to protest the tax
laws of this country and espouse their own misguided views.
A petition to the Tax Court is frivolous "if it is contrary
to established law and unsupported by a reasoned, colorable
argument for change in the law". Coleman v. Commissioner, 791
F.2d 68, 71 (7th Cir. 1986). Petitioners' position as set forth
in the petition, motion for summary judgment, and other filings
consists solely of stale and time-worn tax protester rhetoric.
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