- 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.
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