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extenuating circumstances are simply irrelevant.6 See Estate of
Ruben v. Commissioner, 33 T.C. 1071, 1072 (1960); see also
Grosshandler v. Commissioner, supra at 21.
In view of the foregoing, we hold that petitioner is liable
for the additions to tax under section 6654 as determined by
respondent in the notice of deficiency.
E. Penalty Under Section 6673
At trial, respondent orally moved for the imposition of a
penalty against petitioner pursuant to section 6673.
As relevant herein, section 6673(a)(1) authorizes the Tax
Court to require a taxpayer to pay to the United States a penalty
not in excess of $25,000 whenever it appears that proceedings
have been instituted or maintained by the taxpayer primarily for
delay or that the taxpayer's position in such proceeding is
frivolous or groundless.
The record in this case convinces us that petitioner was not
interested in disputing the merits of either the deficiencies in
income taxes or the additions to tax determined by respondent in
the notice of deficiency. See Coleman v. Commissioner, 791 F.2d
68, 71 (7th Cir. 1986). Rather, the record demonstrates that
petitioner regards this case as a vehicle to protest the tax laws
of this country and espouse his own misguided views.
6 We should not be understood to imply that petitioner had
reasonable cause or that there were any extenuating circumstances
relating to petitioner’s failure to pay estimated tax.
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