Labelgraphics, Inc. - Page 34

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          the year under consideration, respondent provided guidance                  
          totaxpayers by means of Notice 90-20, 1990-1 C.B. 328, and Rev.             
          Proc. 90-16, 1990-1 C.B. 477.10                                             
               Rev. Proc. 90-16, section 4(b)(4), 1990-1 C.B. at 478,                 
          provides that, for purposes of reducing any understatement of               
          income tax under section 6662(d), additional disclosure of facts            
          with respect to an issue involving the reasonableness of                    
          officers' compensation is unnecessary, where the Schedule E                 
          (Compensation of Officers) to the Form 1120 is completed in a               
          clear manner and in accordance with its instructions.  Section              
          4(b)(4) of Rev. Proc. 90-16 further requires that the time                  
          devoted by the officer to the business be expressed as a specific           
          percentage.                                                                 
               In addition, section 6664(c)(1) provides that a penalty                
          under section 6662 shall not be imposed on any portion of an                
          underpayment if the taxpayer shows reasonable cause for such                

               9(...continued)                                                        
          treatment of the item.  However, this amendment is effective only           
          for returns the due dates for which (determined without regard to           
          extensions) are after Dec. 31, 1993, and is not applicable to the           
          instant case.  OBRA 1993, sec. 13251(b), 107 Stat. 531.                     
          Petitioner's return for the year ended June 30, 1990, was due on            
          or before Sept. 15, 1990.  Sec. 6072(b).                                    
               10Sec. 1.6662-4(e) and (f), Income Tax Regs., is not                   
          applicable because they were issued to apply prospectively with             
          respect to income tax returns due after Dec. 31, 1991.  See T.D.            
          8381, 1992-1 C.B. 374, 375.  However, absent further guidance,              
          taxpayers may rely on the rules set forth in Notice 90-20, 1990-1           
          C.B. 328, 330, and Rev. Proc. 90-16, 1990-1 C.B. 477.                       





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