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the correct deficiency amount for 1993.
Respondent also determined that petitioner is liable for
additions to tax pursuant to section 6654 for failure to pay
estimated taxes. If the payments of tax through withholding or
the payment of estimated quarterly tax payments during the course
of the year are not equal to the statutorily required amount then
imposition of this addition to tax is automatic, unless one of
the statutory exceptions applies to the taxpayer. See sec.
6654(a); Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).
The burden of qualification for such exception is on the
petitioner. See Habersham-Bey v. Commissioner, 78 T.C. 304, 319-
320 (1982). Petitioner has failed to show he qualifies for any
exception. Accordingly, we hold that petitioner is liable for
additions to tax under section 6654 for the years 1994 and 1995.
Penalties
Section 6673 permits this Court to award a penalty of up to
$25,000 to the United States when the taxpayer has maintained or
instituted an action primarily for delay or the taxpayer’s
position is frivolous or groundless. See sec. 6673.
This is not the first time petitioner has asserted baseless
arguments and used delay tactics. Petitioner previously made the
same frivolous arguments in this Court and was admonished for
“[presenting] to the Court nothing more than tax protester
rhetoric and legalistic gibberish, which have absolutely no merit
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