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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.
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