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any underpayment of estimated taxes, unless petitioners can prove
that they meet one of the exceptions set forth in section
6654(e). See Recklitis v. Commissioner, 91 T.C. 874, 913 (1988);
Reichenbach v. Commissioner, T.C. Memo. 1998-42; Tillman v.
Commissioner, T.C. Memo. 1996-8. Because petitioners have not
shown that any one of these exceptions applies, we sustain
respondent’s determination on this issue.
All arguments made by petitioners but not discussed herein
have been rejected as without merit.12 Accordingly,
Decision will be entered
for respondent.
12 Many of petitioners’ submissions to this Court contain
frivolous and groundless tax protestor rhetoric that has been
rejected repeatedly by this and every other Court that has
considered it. We admonish petitioners that advancing similar
arguments in this Court in the future may subject them to a
penalty under sec. 6673(a) of up to $25,000.
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