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respect to the section 6654 addition to tax requires the
Commissioner, at a minimum, to produce evidence that a taxpayer
had a required annual payment under section 6654(d). Respondent
did not do so. Consequently, respondent’s determination
regarding the section 6654 addition to tax is not sustained.
III. Section 6673 Penalty
Section 6673(a)(1) authorizes this Court to require a
taxpayer to pay the United States a penalty, not to exceed
$25,000, if it appears that the taxpayer has instituted or
maintained a proceeding primarily for delay or that the
taxpayer’s position is frivolous or groundless. A taxpayer’s
position is frivolous or groundless if it is “‘contrary to
established law and unsupported by a reasoned, colorable argument
for change in the law.’” Williams v. Commissioner, 114 T.C. 136,
144 (2000) (quoting Coleman v. Commissioner, 791 F.2d 68, 71 (7th
Cir. 1986)).
Petitioner’s arguments regarding such things as his
obligation to file a Federal income tax return and the effects of
the Paperwork Reduction Act on his tax reporting and payment
obligations are contrary to well-established law and are
frivolous. Although we provided petitioner with ample warning of
the potential implications of continuing to assert those
frivolous and groundless arguments, petitioner did not abandon
his arguments or acknowledge his liability for income tax on the
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