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v. Commissioner, 99 T.C. 202, 222 (1992). Petitioner reported a
tax liability in 1998 of $9,258 and owed tax in each of years in
issue, yet failed to make any estimated payments. We therefore
hold that petitioner is liable for the addition to tax under
section 6654 for taxable years 1999 through 2002.
Section 6673(a)(1) provides that this Court may require the
taxpayer to pay a penalty not in excess of $25,000 whenever it
appears to this Court: (a) The proceedings were instituted or
maintained by the taxpayer primarily for delay; (b) the
taxpayer’s position is frivolous or groundless; or (c) the
taxpayer unreasonably failed to pursue available administrative
remedies. Respondent has moved that the Court impose a penalty
in the instant case. The record indicates that petitioner was
warned that this Court could impose a penalty if he persisted in
raising frivolous tax protester arguments. Despite being warned,
petitioner raised frivolous arguments throughout the Appeals
process, in his petition to this Court, and in his briefs.
Accordingly, we shall impose a $10,000 penalty on petitioner
pursuant to section 6673.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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