Wesley W. and Patsie Burnett - Page 19




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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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