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Section 6654(a) provides for an addition to tax in the case
of any underpayment of estimated tax by an individual. This
addition is mandatory absent a showing by the taxpayer that one
of the statutory exceptions applies. See Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980).
Petitioner did not pay any estimated tax for 1993, and he
has not shown that any exceptions apply. Accordingly, the
section 6654 addition applies, determined in accordance with the
rest of this opinion.
VI. Respondent’s Motion for Sanctions Under Rule 104
Approximately 2 weeks before trial, respondent moved for
sanctions under Rule 104(c), in response to petitioner’s failure
to participate in discovery and to comply with the Court’s orders
concerning discovery. At trial, respondent stated that the
stipulations entered into by the parties had rendered this motion
moot. In light of the stipulations and our holdings in this
case, we agree with respondent. Respondent’s motion will be
denied as moot.
VII. Respondent’s Motion for a Penalty Under Section 6673
Section 6673(a)(1) provides that whenever it appears that
the taxpayer has instituted or maintained proceedings in this
Court primarily for delay, or the taxpayer’s position in such
proceedings is frivolous or groundless, or the taxpayer
unreasonably failed to pursue available administrative remedies,
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