- 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 modelPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011