John Robert Forrest - Page 5

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          total liability required under the statute.  Sec. 6654(a);                  
          Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992).                      
          Petitioner bears the burden of proving his entitlement to any               
          exception.  Habersham-Bey v. Commissioner, 78 T.C. 304, 319-320             
               Petitioner did not make any estimated tax payments for 1992,           
          1993, or 1994, nor has he shown that any of the statutory                   
          exceptions are applicable in this case.  We therefore hold that             
          petitioner is liable for the section 6654(a) additions to tax for           
          1992, 1993, and 1994.                                                       
               The fourth issue for decision is whether we should impose a            
          penalty on petitioner pursuant to section 6673(a).                          
               Whenever it appears to this Court that proceedings before it           
          have been instituted or maintained by the taxpayer primarily for            
          delay or the taxpayer's position in such proceeding is frivolous            
          or groundless, the Court, in its discretion, may require the                
          taxpayer to pay to the United States a penalty not in excess of             
          $25,000.  Sec. 6673(a)(1)(A) and (B).  A position maintained by a           
          taxpayer in the Tax Court is frivolous "if it is contrary to                
          established law and unsupported by a reasoned, colorable argument           
          for change in the law."  Coleman v. Commissioner, 791 F.2d 68, 71           
          (7th Cir. 1986).                                                            
               We find that petitioner's arguments made in his trial                  
          memorandum and his objection at trial to his participation in the           
          Social Security system are clearly frivolous.  Petitioner has               

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