- 13 - petitioner to show that respondent’s determination of the additions is incorrect. See id. at 447. By the petition and the amended petition, petitioner as much as concedes that he filed no return for 2001. The transcript of account confirms that he filed no return for 2001, and we so find. Respondent has carried his burden of production, and petitioner has failed to prove that respondent’s determination of the section 6651(a)(1) addition to tax is incorrect. The transcripts of account also show that petitioner made no payments of estimated tax for 2001 and filed no return for 2000, and we so find. Respondent has carried his burden of production, and petitioner has failed to prove that respondent’s determination of the section 6654 addition to tax is incorrect. V. Section 6673(a)(1) Penalty In pertinent part, section 6673(a)(1) provides a penalty of up to $25,000 if the taxpayer has instituted or maintained proceedings before the Tax Court primarily for delay or the taxpayer’s position in the proceeding is frivolous or groundless. “The purpose of section 6673 is to compel taxpayers to think and to conform their conduct to settled principles before they file returns and litigate.” Takaba v. Commissioner, 119 T.C. 285, 295 (2002). “A taxpayer’s position is frivolous ‘if it is contrary to established law and unsupported by a reasoned, colorable argument for [a] change in the law.’” Id. at 287 (quotingPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007