- 7 - Estate of Ruben v. Commissioner, 33 T.C. 1071, 1072 (1960). Petitioner did not remit any estimated tax payments for 2002 and has not shown that any of the statutory exceptions are applicable. Respondent’s determination as to the addition to tax under section 6654(a) is sustained. 4. Section 6673 Sanctions As indicated at trial, respondent filed a Motion for Sanctions to impose a penalty on petitioner pursuant to section 6673(a)(1). Petitioner made frivolous arguments in his petition, at trial, and in a memoranda to this Court. Petitioner’s brief only made more groundless arguments in response to respondent’s Motion. Under these circumstances, we see no need to catalog petitioner’s arguments and painstakingly address them. As the Court of Appeals for the Fifth Circuit has remarked: “We perceive no need to refute these arguments with somber reasoning and copious citation of precedent; to do so might suggest that these arguments have some colorable merit.” Crain v. Commissioner, 737 F.2d 1417 (5th Cir. 1984). Section 6673(a)(1) authorizes the Tax Court to require a taxpayer to pay to the United States a penalty not in excess of $25,000 whenever it appears that proceedings have been instituted or maintained by the taxpayer primarily for delay or that the taxpayer’s position in such proceeding is frivolous orPage: Previous 1 2 3 4 5 6 7 8 9 Next
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