Paula M. Olsen - Page 7

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          by an individual".  There is no exception for relief based upon             
          reasonable cause and lack of willful neglect.  Subject to certain           
          exceptions provided by statute, this addition to tax is otherwise           
          automatic if the amounts of the withholdings and estimated tax              
          payments do not equal statutorily designated amounts.                       
          Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992).                      
          Petitioner's situation does not fall within any of these                    
          statutory exceptions.  Respondent, therefore, is sustained on the           
          sections 6651(a)(1) and 6654 additions to tax.                              
               Finally, respondent moved for a penalty against petitioner             
          under section 6673.  Section 6673(a)(1) authorizes this Court to            
          require a taxpayer to pay a penalty to the United States, in an             
          amount not to exceed $25,000, whenever it appears that                      
          proceedings have been instituted or maintained by such taxpayer             
          primarily for delay, or that the taxpayer's position in a                   
          proceeding is frivolous or groundless.  A petition 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).            
          At trial, petitioner acknowledged that she had filed income tax             
          returns up to 1994.  She had been employed for 23 years as a                
          schoolteacher and was retired during the years at issue.  She               
          quite frankly testified at trial that her views on the Internal             
          Revenue Service had "soured" after she and her husband were made            

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