David J. Wierdsma - Page 4

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          Thus, we reject petitioner's argument.  Consequently, and in                 
          light of the fact that petitioner has not introduced any evidence            
          to show that respondent's determinations are erroneous, we find              
          for respondent with respect to the deficiencies.  Rule 142(a).               
               Respondent also determined that petitioner is liable for                
          additions to tax pursuant to sections 6651(a)(1) and 6654 for the            
          taxable years 1993 and 1994.  Section 6651(a)(1) imposes an                  
          addition to tax for failure to file a timely return, unless the              
          taxpayer establishes that the failure did not result from                    
          "willful neglect" and that the failure was due to "reasonable                
          cause".  Section 6654 imposes an addition to tax on individuals              
          for any underpayment of estimated tax.  Petitioner has made no               
          argument and presented no evidence concerning these additions to             
          tax.  Accordingly, we hold for respondent with respect to the                
          additions to tax.  Rule 142(a).                                              
               As a final matter, we consider whether this Court should                
          award a penalty to the United States under section 6673.  Section            
          6673 grants this Court discretion to award the United States a               
          penalty not to exceed $25,000 at the expense of a taxpayer who,              
          in the opinion of this Court, maintains a proceeding primarily               
          for delay or adopts a position in such a proceeding that is                  
          frivolous or groundless.  In his amended petition, petitioner                
          presented tax protester arguments that can only be categorized as            
          frivolous.  Petitioner, however, while less than the model                   





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