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reasonable explanation for his failure to file. Therefore, we
sustain respondent's determination with respect to the addition
to tax for delinquent filing.
Section 6654(a) imposes an addition to tax for underpayment
of estimated tax by an individual. The amount of this addition
to tax is equal to the amount of the underpayment multiplied by
the underpayment rate established under section 6621 for the
period of the underpayment. The addition to tax under section
6654(a) is mandatory unless petitioner can prove that he complies
with one of the exceptions contained in section 6654(e). See
Baldwin v. Commissioner, 84 T.C. 859, 871 (1985); Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980). Since petitioner has
failed to introduce evidence on this issue, and the record does
not indicate that any of the exceptions in section 6654(e)
applies, we sustain respondent's determination concerning the
addition to tax under section 6654.
Section 6673(a)(1) allows this Court to award a penalty not
in excess of $25,000 when proceedings have been instituted or
maintained primarily for delay, or where the taxpayer's position
is frivolous or groundless; i.e., it is contrary to established
law and unsupported by a reasoned, colorable argument for a
change in the law. See Coleman v. Commissioner, 791 F.2d 68, 71
(7th Cir. 1986). In our opinion, such is the case here, and we
believe that a penalty is appropriate. The positions argued by
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