- 30 - has presented evidence that petitioner’s tax liability exceeded the amounts the various payors withheld. Petitioner failed to pay any estimated tax with respect to the nonemployee compensation Ursuline reported or with respect to the IRA distributions Bank One and Pioneer reported. Petitioner did not file any estimated income tax returns for those years. Petitioner has neither argued nor has she presented any evidence to substantiate that she falls within any of the exceptions to section 6654 discussed in Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). See sec. 6654(e); sec. 301.6654-2, Proced. & Admin. Regs. We sustain the additions to tax under section 6654(a) as determined. Respondent requests that we impose a penalty under section 6673(a)(1) upon petitioner. Section 6673 provides that the Court may impose a penalty of up to $25,000 whenever it appears that-- (A) proceedings have been instituted or maintained by the taxpayer primarily for delay, or (B) the taxpayer’s position is frivolous or groundless. Considering the particular facts and arguments in this case, we find that petitioner had no good faith ground for her argument that she did not receive the income respondent determined. That income is clearly established by the evidence, and petitioner did not attempt to offer any 21(...continued) W-2 that the Orchestra prepared show Federal income tax withheld of $30.17 for 1995 and $79.85 for 1996.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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