- 4 -
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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