- 19 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
Last modified: May 25, 2011