- 2 - Over several years Ps made payments to related foreign corporations without reporting the payments on Forms 1042 or withholding and paying the tax due. Ps sought to avoid additions to tax under secs. 6651(a)(1), 6656(a) and 6653(a), I.R.C., on the grounds, inter alia, that the governing law was complex, that they relied on accountants and counsel, and that they cooperated fully with R as soon as they discovered their mistake. Held: The additions are sustained. Robert E. Miller and Edith S. Thomas, for petitioners. Alexandra E. Nicholaides and Eric R. Skinner, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: These cases were consolidated for purposes of trial, briefing, and opinion pursuant to Rule 141(a).2 Petitioners sought redetermination of deficiencies and additions to tax determined by respondent as follows: Ellwest Stereo Theatres of Memphis, Inc., docket No. 3891-94 Additions to Tax Sec. Sec. Sec. Sec. Year Deficiency 6651(a)(1) 6653(a)(1) 6653(a)(2) 6656 1985 $7,950 $1,988 $398 $4,306 $795 2 All Rule references are to the Tax Court Rules of Practice and Procedure and, unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011