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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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