Carolyn Webb - Page 16

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          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.                                                                 



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