- 14 - were required to make estimated tax payments for their 1995 through 2000 tax years.15 Petitioners do not dispute that they made no estimated tax payments for these years. Further, petitioners do not fall within any of the statutory exceptions to the section 6654 addition to tax. Consequently, we sustain the imposition of section 6654 additions to tax for petitioners’ 1995 through 2000 tax years.16 C. Section 6673(a)(1) Penalty Respondent has not asked that we impose a section 6673(a)(1) penalty, even though petitioners’ filings in this case and their submissions to respondent have included numerous frivolous arguments. At trial, we warned petitioners that we might impose a section 6673(a)(1) penalty if they continued to raise these arguments. After trial, petitioners filed no brief and have not otherwise continued to pursue frivolous arguments in this proceeding. On the assumption that petitioners have heeded our warning, we shall not impose a section 6673(a)(1) penalty. We 15 As previously noted, we consider petitioners to have conceded or waived any issue as to whether respondent properly allocated to Mrs. Rinn a share of Mr. Rinn’s dental practice income, as community property income. 16 In the Rule 155 computation, we anticipate that the parties will make appropriate adjustments to the sec. 6654 additions to tax to account for respondent’s concession that Mr. and Mrs. Rinn should be treated as married persons filing separate returns, with no double counting in Mr. Rinn’s taxable income of community-property items included in the computation of Mrs. Rinn’s taxable income.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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