Regina Bruce - Page 6

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          individual.”  Sec. 6654(a).  Subject to certain statutory                   
          exceptions, the addition to tax is applied if the amount of                 
          withholding and estimated tax payments does not equal statutorily           
          designated amounts.  Niedringhaus v. Commissioner, 99 T.C. 202,             
          222 (1999).  The section 6654 addition to tax is mandatory unless           
          the taxpayer comes within one of the limited statutory                      
          exceptions.  Sec. 6654(e); see Recklitis v. Commissioner, 91 T.C.           
          874 (1988).  Petitioner’s only argument as to why she did not               
          make any estimated payments was that she did not earn taxable               
          income.  Petitioner does not qualify for any of the listed                  
          exceptions.  Sec. 6654(e).  She is, therefore, liable for the               
          section 6654 addition to tax for each of the years at issue.                
               At trial, respondent filed a written motion for the penalty            
          under section 6673(a).  Section 6673 allows the Court to impose a           
          penalty, in an amount up to $25,000, on a taxpayer if the                   
          position or positions asserted by the taxpayer in the case are              
          frivolous or groundless.  Sec. 6673(a)(1)(B).                               
               Petitioner’s positions were those of a classic tax                     
          protester.  Before, during, and after trial, petitioner flooded             
          respondent and this Court with exhibits and inflammatory                    
          affidavits advancing her position that the U.S. tax system is               











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