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for any year that immediately preceded any of the years at issue,
nor did they pay any estimated tax for their years at issue. We
accordingly conclude that respondent has met his burden of
production regarding the section 6654 additions with sufficient
evidence to indicate that petitioners had required annual
payments for each of their years at issue.
We do not find that petitioners are entitled to any of the
statutorily provided exceptions to the section 6654 addition to
tax or that respondent’s determinations were incorrect.
Accordingly, we sustain the additions under section 6654 for each
of petitioners’ years at issue.
Section 6673 Penalty
Respondent has moved for a penalty under section 6673(a)(1).
Whenever it appears to the Court that proceedings have been
instituted or maintained primarily for delay or the taxpayer’s
position in such proceedings is frivolous or groundless, the
Court may require the taxpayer to pay a penalty not in excess of
$25,000. Sec. 6673(a)(1).
Petitioners presented no substantive evidence in support of
their positions. Instead, they advanced numerous frivolous tax-
protester arguments, such as claiming that labor is property that
gives rise to an “even” exchange when it is traded for money and
that income is not defined in the Internal Revenue Code.
Petitioners were warned at trial that their arguments were
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