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allegations deemed admitted by petitioner under Rule 90(c)
establish: (1) Petitioner received taxable income during 1995 in
the amounts determined in the notice of deficiency; (2)
petitioner failed to establish reasonable cause for his failure
to file his income tax return and has provided no basis for his
failure to pay estimated taxes during 1995; and (3) petitioner is
liable for the deficiency and additions to tax for 1995 as
determined by respondent in the notice of deficiency.
In sum, the factual allegations deemed admitted by
petitioner under Rule 90(c) establish that respondent's
determinations with respect to petitioner's liabilities for the
deficiency and additions to tax for 1995 are correct, and we so
hold.
In the absence of any dispute as to a material fact in this
case, we shall grant respondent's motion for summary judgment.
Finally, we consider whether a penalty should be imposed
under section 6673. Section 6673(a)(1) provides that, whenever
it appears to the Tax Court that the taxpayer's position in a
proceeding is frivolous or groundless, the Court may impose a
penalty not in excess of $25,000. This Court has often imposed
such penalties on taxpayers who make frivolous tax protester
arguments. See, e.g., Coulter v. Commissioner, 82 T.C. 580, 584-
586 (1984); Abrams v. Commissioner, 82 T.C. 403, 408-413 (1984);
Wilkinson v. Commissioner, 71 T.C. 633, 639-643 (1979); Philips
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