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determinations of additions to tax under section 6651(a)(1) are
therefore sustained.
B. Section 6654(a)
Section 6654(a) imposes an addition to tax for failure to
make timely estimated income tax payments. Section 6654(e)
contains several computational exceptions to application of the
addition to tax. Petitioner bears the burden of proving that she
paid estimated tax or that any of the exceptions excuse her from
paying estimated tax. See Rule 142(a). The estimated tax
penalty is mandatory, unless petitioner can show that she
qualifies for one of these exceptions. Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980) (citing Estate of Ruben v.
Commissioner, 33 T.C. 1071, 1072 (1960)).
Respondent has determined that petitioner is liable for the
addition to tax under section 6654(a) for each of the years 1983
through 1989 and 1991 through 1993. Petitioner has failed to
show that she had paid estimated tax or that any of the
exceptions apply. Respondent's determinations of additions to
tax under section 6654(a) therefore are sustained.
C. Section 6673(a)(1)
1. Introduction
Section 6673(a)(1) provides that we may impose a penalty of
up to $25,000 where, among other things, a taxpayer has
instituted or maintained proceedings primarily for delay or where
the taxpayer takes positions that are frivolous or groundless.
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