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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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