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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
(1982).
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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