Ellwest Stereo Theatres of Memphis, Inc., et al. - Page 12

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            good faith and with ordinary business care and prudence in                                     
            attempting to comply with its obligations after the deadline for                               
            performance has passed is of little or no direct relevance to the                              
            taxpayer’s liability for the additions to tax under these                                      
            sections.  The burden of proving reasonable cause and the absence                              
            of willful neglect is on the taxpayer.  Rule 142(a).                                           
                  Petitioners advance five arguments.  We will consider each                               
            in turn.                                                                                       
                  1.  Complexity                                                                           
                  First, petitioners argue that the reporting and withholding                              
            obligations that arose from their payments to the foreign                                      
            corporations involve a highly complex interrelationship among                                  
            regulations, administrative guidance, and treaty provisions which                              
            only a very sophisticated taxpayer could reasonably be expected                                
            to comprehend.                                                                                 
                  Complex legal provisions may reasonably be susceptible of                                
            different interpretations.  In some cases taxpayers have                                       
            succeeded in avoiding additions to tax by showing that the                                     
            deficiency resulted from an honest and reasonable                                              
            misunderstanding of complex law.  Metra Chem Corp. v.                                          
            Commissioner, 88 T.C. 654, 661 (1987) (no negligence for purposes                              
            of sec. 6653(a)); Yelencsics v. Commissioner, 74 T.C. 1513,                                    
            1533 (1980) (same); Belz Inv. Co. v. Commissioner, 72 T.C. 1209,                               
            1233-1234 (1979), affd. 661 F.2d 76 (6th Cir. 1981) (same).  That                              
            tax obligations are complex does not necessarily make                                          

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