- 16 - equal or exceed the threshold set forth in section 6654(d). Sec. 6654; Philips v. Commissioner, T.C. Memo. 1995-540, affd. without published opinion 99 F.3d 1146 (9th Cir. 1996). The burden of proof is on petitioners to establish that they qualify for an exception under section 6654(e). Rule 142(a); Philips v. Commissioner, supra. Petitioners do not qualify for any exception. Accordingly, we affirm respondent's determinations of these additions to tax.9 Issue 5. Sanctions Under Section 6673 Prior to trial, respondent filed a motion requesting the imposition of a penalty against each petitioner in the amount of $25,000 under section 6673(a), on the ground that petitioners failed to comply with the Court's orders and rules in preparing these cases for trial, and because they instituted the proceedings primarily for delay. Petitioner, in response, continued to assert groundless tax protester arguments. We begin by noting that petitioners are not strangers to this Court. Rather they have a well established history as tax protesters. In fact, the petitions originally filed in this case made various frivolous and groundless allegations, which failed to address the issues mentioned in respondent's notices of deficiency sent to petitioners. Petitioner raised similar 9 With respect to Carolyn Webb, the additions to tax imposed on her pursuant to sec. 6654 are limited to the community property income attributed to her by respondent in the notice of deficiency.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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