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Respondent's determinations of additions to tax under section
6651(a)(1) are sustained.
B. Section 6654(a)
Section 6654(a) imposes an addition to tax for failure to
make timely estimated income tax payments. Section 6654(e)
contains exceptions to application of the addition to tax.3
Petitioner bears the burden of proving that she paid estimated
tax or that any of the exceptions apply. See Rule 142(a).
Petitioner concedes that she paid no tax, and she has not
proven that any of the exceptions apply. Again, petitioner only
offers unreasonable tax-protester arguments to justify her
failure to comply. Petitioner has not carried her burden of
proof. Respondent's determinations of additions to tax under
section 6654(a) are sustained.
III. Penalty
Respondent orally moved that we impose a penalty on
petitioner pursuant to section 6673(a)(1). Section 6673(a)(1)
provides that we may impose a penalty of up to $25,000 where,
among other things, a taxpayer has instituted or maintained
proceedings primarily for delay or where the taxpayer takes
positions that are frivolous or groundless. A taxpayer's
position is frivolous "if it is contrary to established law and
unsupported by a reasoned, colorable argument for change in the
3 For some of the years in issue, different subsections of
sec. 6654 contain the exceptions.
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