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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 or
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